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Perdaman Chemicals andFertilisers

Report for Collie Urea PlantPublic Environmental ReviewSupplement and Response to

Submissions

December 2009

61/23685/12723 Collie Urea PlantPublic Environmental Review Supplement and Response to Submissions

Contents

1. Introduction 2

1.1 Purpose of the Document 2

1.2 Project Design Status 2

1.3 PER Submission Consultation 3

1.4 Structure of the Document 3

2. Air Quality Modelling 4

2.1 Results 4

2.2 Conclusions 5

3. Spring Flora Survey 6

3.1 Desktop Assessment 6

3.2 Survey Results 9

3.3 Potential Impacts 10

4. Cooling Alternatives 12

4.1 Background 12

4.2 Collie Climate 14

4.3 Process Cooling Requirements 15

4.4 Process Air Cooling 16

4.5 Additional Comments on Other Cooling Technologies 17

4.6 Perdaman Actions to Minimise make-up water usage for CollieUrea 18

4.7 Mining Context and Wellington Dam 19

4.8 Conclusion 20

5. Key Amendments to the Proposal 21

5.1 Water Supply Pipeline 21

5.2 Wastewater Disposal 21

6. Response to the Submissions 23

6.1 Air Quality 24

6.2 Noise 29

6.3 Terrestrial Vegetation and Flora 34

6.4 Fauna 42

6.5 Water Supply and Management 43


6.6 Waste 52

6.7 Risk Assessment and Management 56

6.8 Management Plans 64

6.9 Other 66

7. References 71

Table IndexTable 1 Summary of compliance with criteria 1Table 2 Vegetation Type, Extent and Status, Beard (1978)

Vegetation Associations, Shepherd Calculations ofVegetation Extent (Shepherd, 2005). 8

Table 3 Summer Climatic Conditions at Collie 14Table 4 Submission Issues Addressed in this

Supplementary Report 74

Figure IndexFigure 1. Urea Plant Water Balance 13Figure 2 Revised Water Supply Pipeline Arrangement 22

AppendicesA Submission IssuesB Collie Urea Plant PER SubmissionsC Air Quality ReportD Flora Report


Abbreviations

EPA Environmental Protection Authority

EPASU Environmental Protection Authority Services Unit

Mtpa Million tonnes per annum

PER Public Environmental Review

PCF Perdaman Chemicals and Fertilisers


1. Introduction

1.1 Purpose of the DocumentPerdaman Chemicals and Fertilisers, a wholly owned subsidiary of Perdaman Industries, proposes toconstruct a leading edge technology urea production plant, using coal as a feedstock, in the proposedShotts Industrial Park, located 7.5 km east of Collie in south-west Western Australia. Known as theCollie Urea Project, the proposed Perdaman Chemicals and Fertilisers plant will have a nominal capacityof 6,200 tonnes per day (tpd) equating to 2.0 million tonners per annum (Mtpa). The urea will betransported, via rail, for shipment from Berth 5 from the Bunbury Port.

The purpose of this document is to respond to public and government submissions on the Collie UreaProject Public Environmental Review (PER). The PER was published by Perdaman Chemicals andFertilisers, as proponent of the proposed project, for a public review period of eight weeks from 29th

September 2009 through to 24th November 2009.

A total of 15 submissions were received during and following the public review period.

This document provides Perdaman Chemicals and Fertilisers formal response to the environmentalissues raised during the public review.

It also provides additional information in response to previous requests by the Environmental ProtectionAuthority (EPA) Services Unit.

This document (PER Supplement/Response to Final Submission) and the PER comprise the Final PERand is provided to the Western Australian Environmental Protection Authority (EPA) in accordance withEnvironmental Impact Assessment (Part IV Division I) Administrative Procedures 2002 (EPA, 2002).

1.2 Project Design StatusThe proponent advises that since the submission of the PER the following matters have been resolved.

» That the primary water supply for the project will be sourced from Wellington Dam and thatPerdaman will utilise the existing water pipeline from Wellington Dam to transport water 26 km of thetotal 33 km distance required. The balance of the distance will require the construction of a newpipeline from the existing pipelines starting 3.5 km west of the Collie Power station, travelling 7 kmsouth east to the plant site.

» The matter of wastewater discharge has now been addressed. Subject to Environmental Approvals,PCF will now be discharging 3 ML/day of wastewater to the Verve outfall pipeline. Whilst PCF will notbe brine concentrating this wastewater stream and disposing of the solid residue to landfill, someadditional wastewater will be produced and concentrated for solid waste landfill disposal.

There have not been any significant changes to the technology proposed to the design of the Plant thatwere described and assessed in the PER.

Design details regarding the above matters are presented in Section 4 of this Report.


1.3 PER Submission ConsultationDuring the public comment period of the PER, Perdaman Chemicals and Fertilisers conducted two publicconsultation evenings. These meetings were intended to:

» Inform people of the PER document and the submission process;

» Provide people with an opportunity for clarification; and

» Provide an update on the findings in key areas, particularly noise impact, water use and air quality.

Following receipt of the 15 submissions, the Proponent has met with the Environmental ProtectionAuthority Services Unit (EPASU), the Shire of Collie and LandCorp on the 10 December 2009 to discussthe buffer configuration for the proposed Shotts Industrial Park.

As a result of this meeting, Perdaman is to undertake additional noise modelling based on current designinformation and the most realistic design and operational scenarios. The results of this modelling will beprovided to EPA and LandCorp when available.

1.4 Structure of the DocumentThe PER Response to Submissions consists of the following sections:

» Section 2: Results of the air quality re-modelling

» Section 3: Results and discussion of the Spring Flora survey conducted along the proposedwater supply pipeline, coal conveyor easement and wastewater pipeline easement;

» Section 4: Provides a detailed response to the question of cooling options.

» Section 5: Details amendments to the project since submission of the PER;

» Section 6: Provides the list of submissions, comments and the Proponent’s responses;

» Section 7: Outlines additional references to support this document.


2. Air Quality Modelling

Revised air quality remodelling and updating of the Air Quality Assessment report has been completedsubsequent to the PER being issued. The basis for remodelling is elaborated in Section 8.1 of the PERwhere it was noted that The Air Pollution Model (TAPM), Version 4.0.1 was likely to be overstating thepredicted concentrations for nitrogen dioxide (NO2) and ozone (O3).

This conclusion was concurred during the internal and external reviews of the air quality report with theDepartment of Environment and Conservation’s Air Quality Management Branch (AQMB).

GHD, in consultation with the AQMB, contacted CSIRO, the developers of the model to inform them ofthe likely over-prediction and requested advice. CSIRO has since refined the TAPM model and releasedan updated model, Version 4.0.3. GHD remodelled the air quality data using Version 4.0.3. A summaryof outcomes and their implications are reported in this chapter.

The complete revised Air Quality Assessment report is provided in Appendix C.

2.1 ResultsThe revised report only relates to the following criteria pollutants which were remodelled using TAPM (v4.0.3). Other pollutants assessed using TAPM (carbon monoxide) and AUSPLUME are not consideredfurther as the modelling and reported results has not changed.

» Sulphur dioxide (SO2);

» Nitrogen dioxide (NO2);

» Ozone (O3);

» PM10; and

» PM2.5.

2.1.1 Performance Against Air Quality Criteria

Appendix C reports the compliance with relevant air quality criteria as per TAPM model Version 4.0.3.These results are both at the sensitive receptor with the highest predicted concentration as well asacross the modelled domain, for each of the three scenarios, as follows:

» Scenario 1: Existing, approved (under construction) and proposed sources in the Collie airshed;

» Scenario 2: Collie Urea Plant in isolation (normal, steady state operation); and

» Scenario 3: Collie Urea Plant and existing, approved and proposed sources.

From Table 1, the following is observed:

» Scenario 1 and 3, exceedances are predicted for:

– Air NEPM standards across the model domain and at sensitive receptors for 1-hour SO2, 24-hourPM10 and 24-hour PM2.5;

– Kwinana EPP standard across the model domain and at sensitive receptors for 1-hour SO2; and

– Air NEPM standards across the model domain (but not at sensitive receptors) for 1-hour NO2.


» Scenario 2, no exceedances are predicted for across the model domain.

As exceedances of the Air NEPM and Kwinana EPP standards were predicted to occur at sensitivereceptors for SO2, PM10 and PM2.5, the incremental contribution across the airshed was compared forthree facilities, Collie Urea Plant, Bluewaters power station (Stages III and IV) and Muja power station(Stages A and B).

The incremental contribution for the three facilities is calculated as the difference between the predictedconcentrations for the following scenarios:

» Collie Urea Plant - Scenario 3 (Collie Urea Plant and existing, approved and proposed sources) andScenario 1 (existing, approved and proposed sources);

» Bluewaters III and IV - Scenario 3 and Scenario 4 (Collie Urea Plant and existing, approved andproposed sources excluding Bluewaters III and IV); and

» Muja A and B - Scenario 3 and Scenario 5 (Collie Urea Plant and existing, approved and proposedsources excluding Muja A and B).

Examination of the incremental impacts of the three facilities showed:

» Sulphur dioxide:

– Muja A and B was predicted as the main contributor at all but two sensitive receptors for 1-hourSO2, all but two sensitive receptors for 24-hour SO2 and the main contributor at all receptors forannual and 9th highest 1-hour SO2.

– Muja A and B were predicted as the largest contributor to annual SO2 concentrations across themodel domain, contributing a maximum 4.3 g/m3.

– Bluewaters was predicted as the main contributor at two sensitive receptors for 1-hour SO2 andtwo sensitive receptors for 24-hour SO2.

– Bluewaters III and IV were predicted to reduce annual SO2 concentrations by up to 3.5 g/m3.Bluewaters III and IV will include installation of two new 150 m tall stacks which will accept fluegases from the existing Bluewaters I and II. Increasing the stack height will lead to decreasedconcentrations due to improved dispersion of emissions from Bluewaters I and II.

– Collie Urea Plant was not predicted as the main contributor at any sensitive receptor for anyaveraging period.

– Collie Urea Plant was predicted as a minor contributor to annual SO2 concentrations, contributinga maximum of 1.0 g/m3.

» Particulate matter as PM10 and PM2.5:

– Muja A and B was predicted as the main contributor at all sensitive receptors for 24-hour andannual PM10 and 24-hour and annual PM2.5.

– Muja A and B were predicted as the largest contributor to annual PM10 and annual PM2.5

concentrations, contributing 8.3 and 2.2 g/m3, respectively.

– Bluewaters and the Collie Urea Plant were not predicted as the main contributor at any sensitivereceptor for any averaging period.

– Bluewaters III and IV was predicted as a very minor contributor to annual PM10 and annual PM2.5



– Collie Urea Plant was predicted as a minor contributor to annual PM10 and annual PM2.5



Table 1 Summary of compliance with criteria

Predicted maximum concentration ( g/m3)Pollutant Averaging

period 1 Criteria Basis At sensitivereceptor % of criteria Compliance Across model

domain% ofcriteria Compliance

Scenario 1 – Existing, approved and proposed sources

1-hour 572 Air NEPM 1128.2 197% û 2,934.9 513% û

24-hour 229 Air NEPM 162.8 71% ü 211.4 92% ü

Annual 57 Air NEPM 9.0 16% ü 12.0 21% üSulphur dioxide

1-hour 350 KwinanaEPP 538.1 154% û 655.2 187% û

1-hour 247 Air NEPM 260.4 105% û 321.3 130% ûNitrogen dioxide

Annual 62 Air NEPM 4.6 7% ü 11.8 19% ü

1-hour 214 Air NEPM 78.5 37% ü 99.2 46% üOzone

4-hour 172 Air NEPM 69.1 40% ü 86.4 50% ü

PM10 24-hour 50 Air NEPM 149.1 298% û 182.9 366% û

PM2.5 24-hour 25 Air NEPM 42.6 171% û 51.2 205% û

Carbonmonoxide 8-hour 11,254 Air NEPM 114.4 1% ü 221.6 2% ü

Scenario 2 – Collie Urea Plant

1-hour 572 Air NEPM 17.8 3% ü 30.2 5% ü

24-hour 229 Air NEPM 6.1 3% ü 14.0 6% ü


1-hour 350 KwinanaEPP 11.9 3% ü 25.1 7% ü

1 Assessed at maximum, except 1-hour SO2 Kwinana EPP, assessed at 99.9th percentile (9th highest)





1-hour 247 Air NEPM 25.1 10% ü 28.0 11% üNitrogen dioxide


1-hour 214 Air NEPM 50.4 24% ü 51.3 24% üOzone

4-hour 172 Air NEPM 47.8 28% ü 48.6 28% ü

PM10 24-hour 50 Air NEPM 35.3 71% ü 45.9 92% ü

PM2.5 24-hour 25 Air NEPM 19.7 79% ü 21.6 86% ü


PM10 (as urea) 24-hour 50 Air NEPM 4.4 3 8.8% ü 13 26% ü

Ammonia 3-minute 600 SEPP-AQM 57 9.5% ü 143 24% ü

Hydrogensulphide 3-minute 470 SEPP-

AQM 4.3 0.9% ü 33 7.0% ü

Polycyclicaromatichydrocarbons

3-minute 0.73 SEPP-AQM 0.00017 0.02% ü 0.00022 0.03% ü

Benzene 3-minute 53 SEPP-AQM 1.7 3.2% ü 10.2 19% ü

Cumene 3-minute 39 SEPP-AQM 1.7 4.4% ü 10.2 26% ü

Cyclohexane 3-minute 35,000 SEPP-AQM 1.7 0.005% ü 10.2 0.03% ü

Ethyl benzene 3-minute 14,500 SEPP-AQM 1.7 0.01% ü 10.2 0.07% ü

Formaldehyde 3-minute 40 SEPP-AQM 1.7 4.3% ü 10.2 26% ü





n-Hexane 3-minute 5,900 SEPP-AQM 1.7 0.03% ü 10.2 0.17% ü

Toluene 3-minute 650 SEPP-AQM 1.7 0.26% ü 10.2 1.6% ü

Xylene 3-minute 350 SEPP-AQM 1.7 0.49% ü 10.2 2.9% ü

Arsenic 3-minute 0.17 SEPP-AQM 0.00010 0.06% ü 0.00021 0.13% ü

Cadmium 3-minute 0.033 SEPP-AQM 0.00005 0.15% ü 0.00011 0.32% ü

Chromium 3-minute 0.17 SEPP-AQM 0.00001 0.01% ü 0.00002 0.01% ü

Lead 1-hour 3.0 SEPP-AQM 0.00012 0.004% ü 0.00024 0.01% ü

Nickel 3-minute 0.33 SEPP-AQM 0.00002 0.005% ü 0.00004 0.01% ü

Mercury 3-minute 0.33 SEPP-AQM 0.00019 0.06% ü 0.00043 0.13% ü

Scenario 3 – Collie Urea Plant and existing, approved and proposed sources

1-hour 572 Air NEPM 1165.3 204% û 2826.4 494% û

24-hour 229 Air NEPM 158.4 69% ü 212.1 93% ü


1-hour 350 KwinanaEPP 551.6 158% û 649.8 186% û

1-hour 247 Air NEPM 248.0 100% û 311.6 126% ûNitrogen dioxide


Ozone 1-hour 214 Air NEPM 81.1 38% ü 101.5 47% ü





4-hour 172 Air NEPM 69.1 40% ü 89.1 52% ü

PM10 24-hour 50 Air NEPM 144.6 289% û 180.3 361% û

PM2.5 24-hour 25 Air NEPM 41.5 166% û 50.5 202% û



2.2 ConclusionsThe outcomes of this remodelling draw the same conclusions as those presented in the original PER.

The airshed modelling, inclusive of adopted ambient background levels, shows for:

– Scenario 1 and 3, exceedances are predicted for:

o Air NEPM standards across the model domain and at sensitive receptors for 1-hour SO2,24-hour PM10 and 24-hour PM2.5;

o Kwinana EPP standard across the model domain and at sensitive receptors for 1-hourSO2; and

o Air NEPM standards across the model domain (but not at sensitive receptors) for 1-hourNO2.

– Scenario 2, no exceedances are predicted across the model domain.

Overall results also remain the same where it was concluded that:

» There are significant exceedances of the Air NEPM standards predicted at sensitive receptors withinthe Collie airshed for 1-hour SO2, 24-hour PM10 and 24-hour PM2.5;

» There are significant exceedances of the Kwinana EPP standard predicted at sensitive receptorswithin the Collie airshed for 1-hour SO2,;

» In each case, emissions from Muja A and B are the main contributor to concentrations predicted andAir NEPM and Kwinana EPP exceedances;

» Bluewaters III and IV and the Collie Urea Plant contribute very little to predicted concentrations andAir NEPM and Kwinana EPP exceedances at sensitive receptors in the Collie airshed;

» Collie Urea Plant is a source of ammonia (24% of the SEPPAQM design criteria), hydrogen sulphide(7.0% of the SEPPAQM design criteria), volatile organic compounds (< 4.5% of the SEPPAQMdesign criteria at the nearest sensitive receptors), heavy metals (< 0.16% of the SEPPAQM designcriteria at the nearest sensitive receptors) and urea (26% of the Air NEPM standard as particulatesPM10) in the Collie airshed, with predicted concentrations compliant with relevant criteria (referAppendix C); and

» Collie Urea Plant is predicted to increased deposition of nitrogen in the form of urea and nitrogendioxide, with total deposited nitrogen complying with relevant criteria. The predicted maximum24hour PM10 (as urea) concentration is 13 µg/m3 (26% of the Air NEPM standard).

» The predicted maximum urea deposition of 11.6 kg/ha/year equates to 5.4 kg/ha/year total depositednitrogen. Deposition of nitrogen (from nitrogen dioxide) was reported as 3.7 kg/ha/yr. The predictedmaximum total nitrogen deposition due to urea and nitrogen dioxide deposition is 9.1 kg/ha/yr. Thecritical load where harmful effects on an ecosystem are expected is cited as being in the range of 10to 20 kg/ha/year total deposited nitrogen which is above the totals estimated.


3. Spring Flora Survey

Perdaman undertook a Spring Flora and Vegetation Evaluation Survey of the proposed Urea Plant site,the conveyor from the Muja coal mine to the Shotts Industrial Park, the wastewater pipeline from ShottsIndustrial Park to the Collie Power Station and a water supply pipeline from Wellington Dam to the ShottsIndustrial Park. This was undertaken during the week 19th October to 23rd October 2009.

The findings of this survey were combined with those from the 2007 survey of the Shotts Industrial Parkand winter 2009 surveys of the Urea Plant site, the proposed site at Bunbury Port adjacent to Berth 5and the water supply pipeline. The final Flora and Vegetation Survey Report is provided in Appendix D.

The December Flora and Vegetation Survey Report details the findings of the desktop and field studiesand provides advice with respect to statutory process and any issues that may affect the proposeddevelopment.

The following is a summary of the investigation:

» Four main vegetation associations were observed within the Study Area: Jarrah Woodland; Banksia/Sheoak Woodland; Wetlands / River Crossings; and Degraded / Cleared Areas

» The vegetation extent within the proposed Urea Plant, the proposed conveyor, wastewater pipelineand water supply pipeline is considered of ‘Least Concern’, with approximately 60 per cent of the pre-European extent of remaining. The vegetation is well represented at a local scale, within the CollieState Forest, Wellington National Park and Harris River State Forest.

» Vegetation in the south-east corner of the Urea Plant site and adjacent to the disused sand quarry willremain to protect populations of Priority flora and significant vegetation types.

» Generally, the vegetation within the Urea Plant site was in Very Good condition. However a longhistory of disturbances and clearing has resulted in some areas being completely degraded.

» No TECs were noted within the Study Area or within the vicinity of the survey areas.

» No DRF was recorded within the Study Area.

» The Study Area is not located within an Environmental Sensitive Area.

» Two areas of wetland vegetation located adjacent to the Urea Plant site support the Priority 4 species,Pultenaea skinneri and Acacia semitrullata. The Pultenaea skinneri species was identified asoccurring within the Study of the Urea Plant in the wetland vegetation which encroaches along thesouth western boundary south of the sand quarry.

» There was no flora or vegetation of significance associated with the proposed water supply andwastewater pipelines and the conveyor alignments.

» There was no flora or vegetation of significance associated with Berth 5 of the Bunbury Port. The onlyspecies of note was Blackberry, Rubus ulmifolia which was identified along the fence line adjacent toBerth 5.

3.1 Desktop AssessmentBeard (1979) has mapped the vegetation of the survey area at a scale of 1:250,000. This mappingshows the survey area to occur within the Menzies botanical district of the South-western Botanical


Province. According to Beard (1979) the vegetation within the Survey area is Medium forest: jarrah-marri.

Mattiske and Havel (1998) mapped the vegetation in the area as part of the Regional Forest Agreement.The Cardiff, Collie, Helena, Dwellingup and Hester, Murray, Yaragil and Muja vegetation complexesoccur within the survey area. These are described as follows:

Uplands

» Collie: Open forest of Eucalyptus marginata subsp. marginata - Corymbia calophylla – Allocasuarinafraseriana on gravely – sandy upland soils in the subhumid zone. (71% of pre-European extentremaining);

» Cardiff: Open woodland of Allocasuarina fraseriana – Banksia spp. – Xylomelum occidentale –Nuytsia floribunda on sandy soils on valley slopes in the subhumid zone. (54% of pre-Europeanextent remaining);

» Helena: Tall Open Forest of Corymbia calophylla with Eucalyptus patens on lower and Eucalyptusmarginata subsp. marginata on upper slope;

» Dwellingup and Hester Complex: Open Forest of Eucalyptus marginata subsp. marginata andCorymbia calophylla on gravely loam on residual upland surface; (88% of pre-European extentremaining);

» Murray: Tall Open Forest of Eucalyptus patens and Corymbia calophylla on dark brown gravellyloams on the floors of major valleys; and

» Yarragil: Open Forest of Eucalyptus marginata subsp. marginata and Corymbia calophylla redbrown gravelly loam over clay on the lower slope and floor of a minor valley.

Depressions and Swamps

» Muja: Open woodland of Melaleuca preissiana – Banksia littoralis – Banksia ilicifolia with someEucalyptus patens on moister sites, Banksia spp on drier sites of valley floors in the subhumid zone.(51% of pre-European extent remaining).

3.1.1 Vegetation Extent and Status

A vegetation type is considered underrepresented if there is less than 30 per cent of its originaldistribution remaining. From a purely biodiversity perspective, and not taking into account any other landdegradation issues, there are several key criteria now being applied to the clearing of vegetation (EPA,2000)

» The “threshold level” below which species loss appears to accelerate exponentially at an ecosystemlevel is regarded as being at a level of 30% of the pre-European/ pre-1750 extent of the vegetationtype;

» A level of 10% of the original extent is regarded as being a level representing Endangered; and

» Clearing which would put the threat level into the class below should be avoided. Such status can bedelineated into five (5) classes, where:

– Presumed Extinct: Probably no longer present in the bioregion

– Endangered*: <10% of pre-European extent remains


– Vulnerable*: 10-30% of pre-European extent exists

– Depleted*: >30% and up to 50% of pre-European extent exists

– Least Concern: >50% pre-European extent exists and subject to little or no degradationover a majority of this area.

* or a combination of depletion, loss of quality, current threats and rarity gives a comparable status

The native vegetation type represented in the survey area; its regional extent and reservation status aredrawn from Shepherd et al. (2005). This is shown in Table 2.

Table 2 Vegetation Type, Extent and Status, Beard (1978) Vegetation Associations, ShepherdCalculations of Vegetation Extent (Shepherd, 2005).

VegetationAssociation

Description Pre-EuropeanExtent (ha)

CurrentExtent (ha)

%Remaining

% CurrentExtent in

ConservationReserves

3 Medium forest:jarrah-marri 1482495.07 913331.84 61.6 30.2

The pre- European extent of the vegetation in the survey area is 61.6 per cent and is considered to be ofLeast Concern, derived from 2005 data. The vegetation is still well represented at a local scale, withinthe Collie State Forest, Wellington National Park and Harris River State Forest. Approximately 90 ha ofthe Site (not including the coal conveyor, waste water and water supply pipes), exhibit this vegetationtype; the remaining is predominantly regrowth and cleared farmland. This 90 ha represents less than0.0001% of the total extent remaining of this vegetation type. Thus the planned clearing should have avery negligible effect on the overall percentage remaining.

In a review of poorly represented vegetation complexes within the System 6 region, Mattiske (2002)identified the pre-European extent remaining only of poorly reserved complexes. Three of thecomplexes, Helena, Murray, and Yarrigal, were not mentioned in the Mattiske (2002) report. Thisindicated these vegetation complexes are not considered to be poorly reserved. Of the remainingvegetation complexes considered to be poorly reserved (ie Collie, Cardiff, Dwellingup/Hester and Muja),all still have greater than 50% of their per-European extent remaining which puts the vegetationcomplexes across the entire study area into the category of “Least Concern’.

3.1.2 Threatened Ecological Communities

Ecological communities are defined as ‘naturally occurring biological assemblages that occur in aparticular type of habitat’ (English and Blythe, 1997). Threatened Ecological Communities (TECs) areecological communities that have been assessed and assigned to one of four categories related to thestatus of the threat to the community, i.e. Presumed Totally Destroyed, Critically Endangered,Endangered, and Vulnerable.

Some TECs are protected under the EPBC Act. Although TECs are not formally protected under theState Wildlife Conservation Act 1950, the loss of, or disturbance to, some TECs trigger the EPBC Act.The EPA’s position on TECs states that proposals that result in the direct loss of TECs are likely torequire formal assessment.


Possible TECs that do not meet survey criteria are added to the DEC’s Priority Ecological Community(PEC) Lists under Priorities 1, 2 and 3. These are ecological communities that area adequately known;are rare but not threatened, or meet criteria for Near Threatened. PECs that have been recentlyremoved from the threatened list are placed in Priority 4. These ecological communities require regularmonitoring. Conservation Dependent ecological communities are placed in Priority 5.

A search was undertaken of the DEC’s TEC database. No known occurrences of TECs were recordedwithin or in the vicinity of the survey area.

No Priority Ecological Communities are known within or in the vicinity of the survey area.

3.2 Survey ResultsThe combined field investigations identified 461 taxa from in 74 families within the survey area.

Considering much of survey area within the proposed Industrial Park, along powerline corridors,conveyor corridors and pipeline routes have experienced a moderate to high level of disturbance, theremaining area of bushland is considered to have high species diversity, though it is relatively similar tolocal native vegetation occurring in the surrounding region.

Previous clearing and disturbances within the survey area have been associated with farming, railwayinfrastructure, haul roads, power lines, pipelines, infrastructure associated with coal mining (e.g.conveyor), historical logging, rubbish dump, sand quarry and roads/tracks.

The vegetation within the old sand quarry (within the Urea Plant site) has recovered to some extenthowever it is unlikely it will return to its original state. This is also the case with the regeneration ofcleared vegetation within the powerline corridors.

The dominant families recorded from the survey area over the two investigations were:

» Papilionaceae (Peas) 43 taxa

» Myrtaceae (Myrtles) 42 taxa

» Mimosaceae (Wattles) 25 taxa

» Asteraceae (Daisies) 24 taxa

» Poaceae (Grasses) 23 taxa

» Proteaceae (banksias etc) 20 taxa

» Orchidaceae (Orchids) 19 taxa

Additionally, the dominant genera recorded were:

» Acacia (Wattles) 25 taxa

» Hibbertia (Buttercups) 11 taxa

» Lepidosperma (Sword-sedges) 10 taxa

» Drosera (Sundews) 10 taxa

» Stylidium (Trigger-plants) 10 taxa

» Leucopogon (Beard-heaths) 7 taxa


» Caladenia (Spider-orchids) 5 taxa

Refer to Appendix D for full list of flora species recorded in the study area.

3.2.1 Significant Flora

Declared Rare Flora

No DRF were identified during the either 2008 field survey. This was further confirmed with no recordingsof known DRF species during the 2009 investigations.

Priority FloraOne Priority 3 species and one Priority 4 species were recorded adjacent to the Site during the 2007survey; these species were not identified within the Site during the 2009 survey.

The Priority 3 species Acacia semitrullata and Priority Four flora species Pultenaea skinneri wereidentified in the 2007 survey. This shrub is generally found in sandy or clayey soils within winter-wetdepressions. Populations of this species were observed within the belt of wetland vegetation whichpushes up into the Shotts Industrial park along the southern edge east of the sand quarry (see Figure 2Appendix D). This area has been given a priority rating of 1 (Figure 5 Appendix D) and Perdaman havesought to retain Priority 1 vegetation on the site.

3.3 Potential Impacts

3.3.1 Flora and Vegetation

The main potential impacts on flora and vegetation are:

» Vegetation clearing. The design of the urea plant has not yet been finalised; however the surveyarea within the Shotts Industrial Park occupies approximately 135 ha. Of this area, approximately 40ha are in ‘Good” condition or better. Mapping and prioritisation of bushland areas has beenconducted and can be seen in Figure 5 (in Appendix D). The majority of the Plant is planned tooccur in areas of ‘Degraded’ and ‘Completely Degraded’ vegetation condition. Areas of Priority 1 and2 are recommended to be left undisturbed. The Site is surrounded by State Forest and vegetation oflike or similar type and condition. The original proposal to duplicate the water supply pipe fromWellington Dam is no longer applicable as the existing water supply pipe will be used as such noclearing or disturbance of native vegetation will occur within the Wellington National Park. Theproposed wastewater pipeline and conveyor from the urea plant will be built in existing servicescorridors. Clearing of native vegetation will be minimal as the width of the corridors for the most partis able to accommodate the proposed conveyor and wastewater pipeline.

» Potential direct and indirect impacts on the populations of conservation significant flora: Pultenaeaskinneri (P4). Areas connected with this species are being retained as a Priority 1 area.

» Potential increase in invasive and declared weed species from clearing and industrial development.These plants will be controlled as declared by the ARRP Act.


» Potential to introduce/spread plant pathogens into adjacent bushland. A Dieback Management Planwill be implemented during clearing to reduce the risk of spreading the disease to uninfested areasoutside of the Site.

3.3.2 Wetlands

Wetland vegetation is shown as 3b on Figure 3 (in Appendix D).

The main impacts on wetlands within the proposed Urea Plant site are:

» Potential clearing of important wetland habitat. Areas of Wetland habitat have been assigned aPriority rating of 1 and will be retained for habitat and vegetation conservation.

» Potential clearing of conservation significant flora: Pultenaea skinneri (P4). Areas associated withthis species, such as wetland vegetation, have been marked as Priority 1 and will be retained.


4. Cooling Alternatives

Several submissions and the community have queried the choice of water cooling over dry (air) cooling.This section addresses these concerns.

4.1 BackgroundThe Collie Urea project has considered various technology options to minimise the use of cooling waterin the process. This world-class facility is committed to the judicious use of water.

In the urea manufacturing facility, cooling is required for different applications, noting that the Collie UreaPlant is primarily a petrochemical facility and not a power plant.

In the coal to urea plant there are exothermic (heat generating) reactions in the Gasification, Shift,Ammonia synthesis, and part of Urea synthesis processes.

The manufacture of urea from coal is a complex staged process and temperature is a critical factor ateach unit operation. Effective and efficient cooling is the key to maintaining product consistency andsafe plant operation. The two media commonly employed for process cooling are air and water.

Water is about 1000 times as dense as air and has a heat capacity that is four times that of air. Thisimplies that for a similar volume of fluid flow, water could recover about 4000 times the energy comparedto air.

The salinity of the supplied water is another significant issue. In order to make saline water fit forpurpose, it is essential to reduce the salt concentration to an acceptable level. The primary source of thissaline water for this project is Wellington Dam. As the Dam is expected to remain the primary source ofwater, the continuous removal of salt from the Dam will ultimately benefit the environment over the longerterm.

Most of the water used is eventually evaporated (cooling duty). Other on-site water users are the variousmanufacturing processes as well as the water required to transport concentrated salts to the existingVerve saline ocean outfall pipeline. Excess salt is recovered as brine for land filling.

Figure 1 presents a snapshot of process flows for water and salt.


DesalinationCoolingwater

Deminwater

Steam genand users

Rain water0.45 Glpa

Wellingtondam6.6 Glpa

ProcessReaction1.65 Glpa

Blow down0.8 Glpa

Make-up2.1 Glpa

Evaporation9.7 Glpa

Water balance:Process Integration and salt handling

1 December 2009 3“Perdaman – Commercial in Confidence”

Concentration

Process

BFW

Condensate~4 Glpa2.2 Glpa

Recovered2.75 Glpa

Salty water3.1 Glpa

Salty water 0.65 Glpa

2.1 Glpa

Saline pipeline1.6 Glpa

7.75 Glpa

DiversionWater6 Glpa

Brine ~0.2 Glpa

Figure 1. Urea Plant Water Balance

The main factors that have led to PCF to choose water cooling are summarised below. The subsequentsections will discuss these factors in detail.

1. The Collie climate favours cooling water for summer months over air. Water temperature exhibitsless fluctuation when compared to air and it is possible to achieve a higher temperature gradient withwater than air.

2. There is greater process stability for the ammonia / urea plant.

3. Air separation is more efficient with lower temperatures from cooling water.

4. Water more effectively condenses ammonia.

5. Air-cooled heat exchangers would require fans to drive the air over the tubes; these contribute to theoverall capital costs as well as environmental impacts that include, land disturbance, noise andemissions (due to additional power utilisation).

Additionally, water usage issues are considered below.

6. Gasification gas clean up requires process water.

7. Water is far more efficient at recovering waste heat through steam generation; steam generationoffsets the significant power requirement of the process. The condensate is recovered and reused.


8. PCF’s desalination scheme will contribute to the reduction of salinity of Wellington Dam water overtime thereby offering significant downstream environmental and economic benefits to the Collie RiverIrrigation District water users.

9. Desalination reduces the cooling water make-up required; the proposed scheme enables water to berecycled 12 times as opposed to 5.5 times traditionally.

10. Gas turbine power generation approach uses ~1/3rd less water than conventional coal powergeneration.

4.2 Collie ClimateThe choice of cooling is influenced by the Collie climate. Collie’s climate typically has hot dry summerdays (low relative humidity), with cool rainy winter days. There is seldom frost.

The cooling system design is mainly influenced by the maximum, not minimum conditions. No specificwinterisation is required for Collie conditions.

The summer conditions (BoM Collie 009628) are described as:

Table 3 Summer Climatic Conditions at Collie

Month December January February March

Mean max temperature ºC 28.3 30.5 30.1 27.3

Decile 9 Maximum temp ºC 35.6 37.8 37.2 33.9

Days > 30ºC 12.4 18.3 14.6 9.4

Mean 3pm wet bulb ºC 17.9 19.4 19.4 17.9

3pm relative humidity 37 37 38 42

Cooling water return 21.5 23 23 21.5

This illustrates that the expected alternative cooling media temperatures for the warmest months are:

» Air - frequently over 30ºC

» Cooling water – max 23ºC inlet

In order for effective cooling, the temperature gradient between the inlet and outlet of the cooling mediumshould be as high as practicable. Table 2 illustrates that water would always provide a highertemperature gradient (at design conditions).

Air temperatures can vary during the course of the day and often this variation can be significant. Theimpact of such changes is harder to control and may result in potential plant upsets. Water temperatureon the other hand varies in a narrow range irrespective of the climatic conditions. This makes it easier tocontrol the process.


4.3 Process Cooling Requirements

4.3.1 Ammonia and Urea

The ammonia and urea synthesis portions of the project use approximately 45% of the cooling waterrequired by the Plant.

Around the world ammonia and urea plants use cooling water for critical process duties. These processduties relate to the condensing of ammonia from gas streams. Condensation is more effective at lowertemperatures, thus favouring direct cooling water over dry or indirect cooling options. The optimumtemperature to condense ammonia at process pressure is below 30ºC. Using ambient air in summer(typically ~ 35ºC) would result in higher ammonia emissions and reduced control capability.

Uncondensed ammonia can lead to increased emissions (losses to flare system) as well as lowerproduction.

Ammonia condensing duty also has a large heat absorption requirement and the higher density of water(1000 kg/m3) versus air (~1.27 kg/m3) results in a high air flow required to match the heat transferrequired.

Thus use of cooling water rather than ambient air results in a more stable ammonia plant operation.

Ammonia synthesis (together with the Shift and Gasification processes) is an exothermic reaction,meaning that waste heat is generated. This heat is most effectively removed as steam which allows therecovered heat to be used for heat and compressor drives.

In a condensing turbine, heat is converted to work and the spent steam is usually condensed with coolingwater. The condensate is typically at ~ 55ºC from vacuum conditions to maximise heat recovery.

This spent steam condensing can be achieved with air, again noting that the temperature approach is~20ºC versus ~30ºC for cooling water. Barring a larger equipment sizing, control is limited by ambientconditions – on a hot day the air cooled condenser is de-rated (ie loses performance).

In urea synthesis, there are two subsequent reactions:

NH3 + CO2à carbamate (1)

Carbamateà urea + H2O (2)

The second reaction results in some process water being recovered, which is returned to the steamsystem to reduce the Boiler Feed Water (BFW) required.

Based on published Licensor data (Uhde, Stamicarbon, Snamprogetti) the Collie Urea Plant coolingwater use is considered comparable to ammonia/urea plants around the world.

4.3.2 Gasification and Gas Treatment

Most of the coal energy is transferred to syngas (ca. 80%) in Gasification, with much of the remainder(ca. 15%) as steam. Waste heat recovery with steam generation allows recovery of waste heat in auseful format. This steam requires boiler feed water (BFW). The process pre-heats the BFW and thesteam recovered in Gasification is largely used to drive the CO2 compressors. In this compressor moststeam is not condensed, but extracted for process use in the Collie Urea Plant.


Gasification also uses recovered Shift condensate as scrubber water for the treated raw syngas. Thewaste water from this process is cleaned and largely re-used in the Gasifier slag bath section. A blowdown containing salts (mainly sodium and chlorides) is sent back to the desalination plant.

In Gas Treatment, water is consumed in the Shift reaction into the process syngas to maximise hydrogenproduction.

CO + H2Oßà H2 + CO2 (Shift reaction)

This water consumption is not returned to the water system, and is made up with demineralised waterproduced from the raw water supplied.

Water cooling is used to cool the Acid Gas Recovery Unit (AGRU) solvent (ADIP-X, by Shell) to improveCO2 and sulphur extraction from the sour (shifted) syngas. The absorbent warms up with load, and isfurther heated to recover the CO2 and sulphur species.

ADIP-X is a modified version of the well known MDEA solvent commonly used in gas treating CO2

removal. This solvent works at close to ambient temperature. Use of cooling water allows a loweroperating temperature, which increases CO2 absorption (loading) compared with air cooling.

4.3.3 Air separation Unit (ASU)

The gasifiers use high purity oxygen (O2) to maximise syngas production, and nitrogen (N2) is used forinerting, pressurisation and process reaction N2 make-up for Ammonia synthesis.

A modern large scale ASU uses cryogenic separation, which involves compression of air with cooling tocryogenic conditions to separate O2 from N2 and argon.

Given sub-zero requirements this compression is sensitive to cooling temperature to removecompression heat as well as provide cooling for the process.

Around the world all ASU’s use cooling water to remove heat – as it allows compact heat exchangers,and provides a lower cooling temperature, which improves compression efficiency between compressorstages.

Air cooling is thus not a practical option for the ASU.

4.3.4 Process impact on water use

From the above, the overall Collie Urea Plant process water usage is ca. 2.1 Glpa out of the 12 Glpaassigned and allowing 1.0 Glpa for saline discharge.

The net cooling water ‘usage’ is thus ~9 Glpa, and it is strongly integrated with process operations.

4.4 Process Air CoolingPCF does use some air fans in the process of heat removal:

» Urea is granulated with air flow, which removes the bulk of the heat of the warm particles.

» Coal Milling and drying recirculates warm combustion air to improve drying over pulverised coal in aclosed system.


4.4.1 Indirect cooling

As an alternative, it is possible to have a separate cooling water circuit (secondary), coupled with aseparate cooling loop (primary) circuit – e.g. Sea water, or air.

Sea water is not considered a practical option for Collie (65 km from the ocean), with a 200m static headrequirement (altitude).

The air option is a hybrid approach. It would require a closed cooling water circuit. The cooling watercould be cooled in an air-cooled heat exchanger as opposed to a cooling tower. While it is possible todesign such a system, there are serious drawbacks with this. For the same amount of cooling duty, onewould need roughly 4000 times the volume of air and the surface area required to achieve maximumcooling is immense. It should also be borne in mind that the ammonia and urea facility designs areproprietary and require liquid-liquid heat exchange. Assuming that the entire cooling duty is to be takenup by an air-cooled heat exchanger, it is estimated that cooling duty would be so large that it wouldrequire about 33 MW to run the fans. Such an air-cooled heat exchanger is estimated to require about500 fans and will occupy a plot area close to 22,000 square metres. This power would have to be madeup by burning more fossil fuels.

A significant problem with this arrangement is impact on plant safety and operability. As discussed inprevious sections, plant operability and as a consequence safety could be comprised if good temperaturecontrol is not achieved. Owing to the scale of the required air-cooled heat exchanger, the probability offailure is higher.

In summary, the environmental footprint as described above, make this option unattractive.

The above analysis supports the need to adopt the benefits of the lower temperature of water comparedwith air at Collie conditions in warmer months, thereby enabling the most stable and effective processcontrol of water cooling.

4.5 Additional Comments on Other Cooling Technologies

4.5.1 Dry cooling

Dry cooling (or more correctly, low water cooling) has been demonstrated by various power stationsaround the world. eg. Kogan Creek claims to use 1/10th of the water of a conventional coal based powerstation.

In context, the dry cooling water usage of Kogan creek technology is ~1/6th of that for Gas TurbineCombined Cycle (GTCC) technology that PCF proposes for power generation. (Gasification enablespower generation via lower water using gas turbine combustion).

Dry cooling, while reducing water consumption does have other environmental impacts:

1. The efficiency of air cooling is lower due to the greater heat absorption capacity of water compared toair. This makes it much more difficult to recover waste heat in complex petrochemical processessuch as that proposed by Perdaman. (This is discussed in Section 4.4.1)

2. The heat approach for cooling water is considerably better - the wet bulb temperature of coolingwater is substantially lower than ambient air temperature. Eg. In the summer months the wet bulb forCollie is below 20ºC, whereas the ambient air can be 35-40ºC. (Refer Section 4.2)


3. This results in a considerably larger ground footprint for air cooling, with the associated land clearingrelated environmental impacts. (Refer Section 4.4.1)

4. Air cooling has a higher power demand (estimated as an additional 30-33 MW for Perdaman – whichresults in additional CO2 and other emissions, plus additional associated cooling water use.

5. The additional power related emissions are dependent on the source of power. Using traditionalCollie power stations, this is 1.0 t/MWh and with additional water use of 2.5m3/MWh equates to 250ktpa CO2 and 0.6 Glpa of (clean) cooling water.

6. This is equivalent to ca. 7% of the Collie Urea Plant’s cooling water load

7. Air cooling fans generate a significant additional noise contribution – given that there is a larger areaimpacted and up to 200 fans required.

4.5.2 Dry condensing

Dry condensing has been applied in Power plants. However PCF is not a power plant. The steam drivesare considerably smaller and have precise process compression duties. The objective of a power stationis to generate power and this is achieved by condensing the steam. In this case, using an air-cooledheat exchanger is viable.

There is limited space around the compressor drives for extensive and consequently it is more difficult tocontrol the air cooling process. This issue therefore leads to a the preferred use of water cooling.

4.6 Perdaman Actions to Minimise make-up water usage for Collie Urea

4.6.1 Lower salt cooling water

PCF is designing raw water desalination to a lower than usual salt level of 200 mg/l for the cooling watermake-up. This compares with 450-550 mg/l typically used as make-up water by existing power plants.The lower salt level is more expensive to achieve but allows an increased number of cooling watercycles, which results in a lower water make-up requirement.

Targeting a blow down wastewater salt concentration of 2,500 mg/l, the PCF approach allowsapproximately 12 cycles, against ~ 5.5 cycles for conventional TDS water. Barring reducing effluent(salts), this reduces the required water make-up by ~1.0 Glpa.

4.6.2 Power generation with combined cycle

The project requires a power supply of approximately 160 MWh. With conventional sub-critical coalbased boilers power generation, water consumption is approximately 2.5 m3/MWh (referenced fromBluewaters Power station (with Collie coal), PER 2005).

PCF is adopting a combined cycle gas turbine for internal power generation, which results in a higheroverall efficiency as well as a reduced steam turbine condensing load. The result of this is that waterconsumption is approximately 62 per cent of the conventional boiler based system – 1.5-1.6 m3/MWh.

This aspect reduces water consumption by 1.1 Glpa for the power portion.


4.6.3 Re-use of steam condensate

The steam system requires blowdown to remove contaminants in the steam system. This water will besent to the cooling water system to reduce cooling water make-up (~10 m3/h).

4.6.4 Re-use of process condensate

The urea synthesis reaction results in water formation. This water is recovered and cleaned and thewater is used to reduce make-up water (roughly 0.6 Glpa).

4.6.5 Re-use of site storm water

Rainfall on the site is collected and treated for re-use as cooling water.

Based on the rainfall and expected process area, the quantity is in the order of 0.4-0.6 Glpa.

4.6.6 Existing Saline pipeline

The existing Verve Energy owned saline pipeline to the ocean, near the Shotts site is well placed toprovide support for the disposal of desalinated Wellington dam and East Collie river saline water.

PCF notes that most of the salts (ca. 80%) it will dispose of are already present in the raw water. Theprocess will likely add some salts –mainly sodium from some caustic, and chlorine from some HCl use.

PCF has requested access to 3-4.5 Ml/d of capacity in the Verve pipeline, depending on the amount ofEast Collie River saline diversion water that is required to be processed to satisfy plant water demands.

4.7 Mining Context and Wellington Dam

4.7.1 Coal mining results in dewatering

Collie coal mining requires dewatering to allow for safe mining – typically in the order of 3 m3 per tonne ofcoal mined. This water removal is not constant, but the portion not used is essentially returned to theCollie water basin.

With PCF consuming 2.6 Mtpa coal, based on the average estimate, the average volume of dewater isapproximately 7 Glpa. This estimate is 2/3rd of PCF’s requirements.

Water associated with mining activities, is returned to the Collie basin. Some of this water is anticipatedto return to Wellington Dam via the river drainage. PCF is not using ground water relying solely onsurface water supply.

4.7.2 Wellington Dam Desalination

Over the past 60 years Wellington dam water quality has deteriorated to a point of marginal use foragriculture irrigation. A TDS close to 1000 mg/l is not suitable for agriculture irrigation.

PCF will desalinate Wellington dam water it has been assigned and effectively annually remove salt fromthe dam. Over time, the dam water quality is expected to improve.

Thus the PCF water usage will have the indirect benefit of desalinating the Wellington dam.

Over time this improvement in water quality will restore the value of irrigation water (Collie River IrrigationDistrict) and potentially to a point where the supply is potable water again.


Air cooling does not offer such potential, and PCF considers that this water desalination benefit has abroader value than the plant.

PCF will also consider accessing some water from the Collie Diversion project. This highly saline wateris diverted from entering the Wellington dam, and desalinated to concentrate the salts

4.8 ConclusionPCF has adopted a proactive approach to water management. This approach subscribes to theprinciples of sustainable use of resources. To this end PCF has adopted world’s best practice withregards to water utilisation that ensures that wherever possible, water is recovered and reused within theprocess and that design innovations are applied to ensure maximum heat recovery and where possiblethe use of air cooling.

The climate, location and proprietary process design are barriers to the inclusion of a greater level of air-cooled heat exchange.


5. Key Amendments to the Proposal

5.1 Water Supply PipelineAgreement in principle has been reached with Water Corporation to enable Perdaman to access theexisting Wellington Dam off-take and pipeline to supply water to the urea plant. This avoids the need toconstruct a new pipeline from the dam and the associated existing corridor disturbance activity.

Of the 33 km length between the dam and the Industrial Park, new pipeline will be required for only 7 kmnorth-west from the Shotts Industrial Site to connect to the existing pipeline. This alignment will remainwithin existing transmission line easements as detailed within the PER (Figure 2).

No construction activity will be required within the Wellington Dam National Park.

Construction of the pipeline from the Collie-Williams Road to the plant will be within existing clearedtransmission line easements and will not require clearing of other than regrowth vegetation < 5 years ofage.

5.2 Wastewater DisposalIn principle agreement has been reached in relation to access to the Verve Energy pipeline for disposalof 3 ML/day of wastewater in accordance with the existing DEC license.

GHD House, 239 Adelaide Terrace Perth WA 6004 T 61 8 6222 8222 F 61 8 6222 8555 E [email protected] W www.ghd.com.au

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G:\61\23685\GIS\mxds\612368512-G008.mxd© 2009. While GHD has taken care to ensure the accuracy of this product, GHD and LANDGATE, GHD, LANDGATE (SLIP), HARLEY SURVEY GROUP make no representations or warranties about its accuracy, completeness or suitability for any particular purpose. GHD and LANDGATE, GHD, LANDGATE (SLIP), HARLEY SURVEY GROUP cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses,damages and/or costs (including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.

LEGEND

0 1 2 3 4 5

Kilometres

Map Projection: Transverse MercatorHorizontal Datum: Geocentric Datum of Australia (GDA)

Grid: Map Grid of Australia 1994, Zone 50

Perdaman Chemicals and FertilisersCollie Urea Project

PipelineFigure 1

Job NumberRevision 0

61-23685-12

17 DEC 2009

and Conveyor Alignmentso Date

Data Source: Landgate: Collie Feb 2008 Mosaic - SLIP 20090626, Bunbury 2008 Mosaic - SLIP 20090628; GHD: Proposed Water Supply Route - 200906, Proposed PCF Coal Conveyor - 20090728, Proposed Wastewater Pipeline - 20090915; Water Corporation: Water Distribution Pipelines - Urban - 20091712; Harley Survey Group: Proposed Fertiliser Plant Boundary - 20090713. Created by: xntan, croach2

1:100,000 (at A3)

!

!!

!!

INDIANOCEAN

CAPEL

COLLIEBUNBURY

BINNINGUP

DONNYBROOK

Locality Map

Proposed Water Supply Pipeline Route

Existing Water Corporation Wellington Dam Pipeline

Proposed PCF Coal Conveyor

Proposed PCF Wastewater Pipeline

Proposed Fertiliser Plant Boundary

mailto:[email protected]

http://www.ghd.com.au


6. Response to the Submissions

Fifteen submissions were received on the PER for the proposed Collie Urea Project. Details on thesesubmissions are provided below. Copies of the submissions are provided in Appendix B.

1. Department of Mines and Petroleum (DMP) – 14 October 2009

2. Private submission dated 4 November 2009

3. Department of Indigenous Affairs (DIA) - 6 November 2009

4. Environmental Regulation (Noise), Department of Environment & Conservation 17 November2009

5. South West Integrated Management (SWIM) - 18 November 2009

6. Shire of Collie - 17 November 2009

7. Private submission dated 23 November 2009

8. Forest Products Commission (FPC) - 23 November 2009

9. Department of Environment & Conservation (Environmental Management Branch) (DEC) - 18November 2009

10. Rural Action Group (RAG) - 23 November 2009

11. Premier Coal - 24 November 2009

12. G Yates - 24 November 2009

13. South West Environment Centre (SWEC) - 24 November 2009

14. Friends of the Earth Southwest WA (FESWA) - 24 November 2009

15. Department of Water (DoW) - 26 November 2009

Each of the received submissions raised issues, provided comment, asked questions and requestedclarification covering a wide range of issues relating to information presented in the PER and to issuesoutside the scope of the PER. The submissions were reviewed by Perdaman Chemicals and Fertilisersand the following responses provided.

For clarity and ease of review, elements of the submissions have been reproduced or paraphrased asappropriate. Elements have been grouped under common headings as a number of submissionsaddressed similar issues.

For each heading, an issue number (in brackets), the submission title is provided in bold, the submissionsection in italics, followed by the proponent’s response. As some submissions were quite detailed,reference to the section of the submission is also provided. A summary of key issues is provided inAppendix A.


Issues not relevant to the PER or environmental assessment process have not been addressed in thisdocument.

6.1 Air Quality (53) South West Integrated Management (SWIM) Issue

Public Health Impact needs to fully explore the issue of atmospheric impacts from the plant andoperations - there are many considerations to cover in this. A full health Impact statement should beprepared by the proponent and all questions raised in the atmospheric contaminants of this report shouldbe addressed

(95) Anonymous Letter Issue

Contaminants that may impact air quality including coal dust and other particulates.

Proponents Response to SWIM and Anonymous Letter Issues

Health impacts will be considered as part of the detailed quantitative risk assessment which will beundertaken with the regulators during detailed design. This is dealt with by the Shire of Collie during theDevelopment Approvals process and is not part of the PER approvals process. Please also refer toresponses relating to risk (Section 6.7).


The risk of particulates for example S or Urea being dispersed into the forested area potentiallydestroying native vegetation.

(136) Rural Action Group (RAG) Issue

RAG does not believe that the PER shows a design that prevents emissions causing an adverseenvironmental impact beyond the boundaries of the site.

Proponents Response to RAG Issue

Perdaman will comply with statutory air emissions regulations as detailed in Section 2.

The predicted maximum urea deposition of 11.6 kg/ha/year equates to 5.4 kg/ha/year total depositednitrogen. Deposition of nitrogen (from nitrogen dioxide) was reported as 3.7 kg/ha/yr. The predictedmaximum total nitrogen deposition due to urea and nitrogen dioxide deposition is 9.1 kg/ha/yr. Thecritical load where harmful effects on an ecosystem are expected is cited as being in the range of 10 to20 kg/ha/year total deposited nitrogen which is above the totals estimated (refer Appendix C for furtherdetails).

Perdaman does not consider that these emissions will lead to adverse environmental impact beyond thesite.


Appendix D Section 7. 1.5 states ammonia emission modelling was done using AUSPLUME. Section 7.3.1 states " Irwin's `rural' wind profile exponents were used". We do not understand this statement andwould like to know if the modelling was applicable to winds and weather in the Collie area , which aredetailed in Appendix D Section 4.3.2 Figures 5-9.



Irwin’s rural wind profile exponents are specific model settings related to the treatment of atmosphericturbulence due to surface roughness and heat exchange. Irwin’s rural profile has been used as the site isa rural setting, with little contribution of heat flux (as would occur from urban areas). The actual wind andweather was based on a local meteorological file, which was validated against observed data and foundto be representative.


RAG request that PCF revisit the statement that: "based on the isolate nature of Collie Urea Plant Siteand surrounding land uses, dust emissions are not considered to represent a significant source ofemissions" Collie is only 7 km from the proposed site and is therefore not an isolated site.


The potential for major dust generation during construction will primarily be restricted to the early stagesof the project during initial earthworks. The surface area of disturbance and consequently potential fordust generation will be significantly smaller that that of surrounding mining areas. Dust control duringconstruction will be a key mitigation, both to reduce off-site impacts but also to maintain a safe andhealthy work environment for the construction workforce. As soon as practicable, exposed areas will betreated and managed, including access roads and internal roads. Dust management will be a keyelement of the construction Environmental Management Plan and will be monitored on a continual basisas detailed below.


RAG requests real time particulate monitoring and reactive mitigation measures are employed for bothbreathable particulates and nuisance dust. RAG requests that all dust monitoring is carried out as perAustralian standards regarding the calibration of equipment and location of monitors.


Perdaman agree’s to undertake real time particulate monitoring as detailed above.


RAG requests that audible alarms are connected to the computerised dust monitoring system so that anyexceedances can be dealt with immediately.


PCF will install Industry-Best-Practice systems when dealing with dust emissions and monitoring.


Has PCF considered limiting construction activities to daylight hours only as respirable dust issues wouldbe worse over night and in the early mornings?



Early construction works including earthworks will be primarily restricted to daylight hours. Initialearthworks will be the primary potential source of dust generation during the construction phase.Nightworks will be limited. Later in the construction program during the plant fitouts, nightwork may beundertaken but this will not be work likely to generate dust.


Would PCF and the EPA confirm that no dust would be emitted in the operational phase of the proposalother than PM10 and PM 2.5 modelled in Appendix D.


PCF is confident that it has identified the possible sources of PM at PM10 and PM2.5 and modelled them.

(169) Premier Coal Issue

The vented waste gas from the product island may have a pungent odour. PCF is requested to assessthe potential impact of waste gas against ambient air quality and that mitigation strategies, includingpossible shutdowns be considered to limit the impact of such an event.

Proponents Response to Premier Coal Issue

All the process vents will be routed to the flare. Hence, no odour issues are anticipated at any phase ofthe operation.


The estimated offsite population appears to have been understated for the PRA and air qualityassessment. Premier Coal requests that a detailed risk assessment is undertaken using more accurateoffsite population data and Premier Coal buildings be considered as sensitive receptors for air qualityassessment before these assessments are made to government.


A comprehensive risk assessment of the plant will be achieved through a Formal Safety Assessmentprocess that runs through the entire design phase. This process will be completed during the safety casedevelopment. The Safety Case process allows extensive review of the risks associated with the plantand control measures implemented and makes an assessment of the operator’s ability for safe operation.Perdaman will consider Premier Coal buildings in all future assessments.

(174) Glyn Yates Issue

Air emissions will need to meet all the established guidelines all of the time. These should be reported tothe community on a quarterly basis through the local press.


Proponents Response to Glyn Yates Issue

Perdaman is committed to meeting air quality regulation requirements and the current proposal iscompliant with these regulations. Perdaman will regularly report to DEC regarding compliance with itslicensing conditions.

6.1.1 Greenhouse Gas and Carbon Sequestration

(16) South West Integrated Management (SWIM) Issue

Alternative carbon capture/offsets schemes should also be subject to full rigour of a PER

Proponents Response to SWIM Issue

Perdaman has committed to the investigation of sequestration options as outlined in the PER. Any suchoptions would be required to undergo appropriate environmental assessment when sufficient details areavailable to allow EPA to evaluate the project.


SWIM would propose that the proponent should commit to binding targets for carbon offsets in the PERand contract to purchasing carbon offsets through 3rd party entities to ensure transparency. Additionallythe proponent should be directed to provide an environmental bond on carbon offsets to ensure the Statehas sufficient coverage on CO2 should technology prove to be unreliable for sequestration.

(194) Anonymous email dated 4 November 2009 Issue

The proponent does not release a figure to how much of its emitted green house gases will be abatedfrom its plant


The proponent mentions investigations into wind farms and bio-diesel in India. Under the proposedCPRS scheme, emissions saving from outside Australia is not permitted to be used to offset emissionsgenerated in Australia


I am interested in what price of carbon the plant becomes unviable for operation and what conditions ofoperation will be placed on this development approval


Details of how the plant plans to interact with the proposed CPSR scheme should be released.

Proponents Response to SWIM and Anonymous email Issues

CO2 is not a classified pollutant and as such is not currently regulated. Perdaman is prepared to committo continuing its contribution to evaluation of the Lower Leseuer geo-sequestration project, but without ameans of achieving binding targets the company cannot commit to them. At the present time there is noclear emission trading scheme and established market price for CO2, nor is there any established


practice by the EPA of imposing such bonds on projects. It would be unfair to the Perdaman project toimpose such a bond in the circumstances, in Perdaman's opinion. In due course it is anticipated that theFederal Government will implement legislation that will enact an emissions trading scheme and from thatpoint forward all CO2 emitters, including Perdaman, will pay a market price for CO2 permits.

As has been reported in local media, the Collie South West Hub carbon storage project (which PCF ifco-funding with the WA Government and other coal industry members) was one of four projects torecently secure Commonwealth Government funding through the Commonwealth Governments CarbonCapture and Storage Flagships program. This funding will enable completion of a pre-feasibility studyinto the suitability of geo-sequestration sites between Bunbury and Mandurah and if successful willposition the project to access a share of $2 Billion of Commonwealth Government funding for a geo-sequestration project development. In anticipation of this, PCF is committing $400 million in its project tocapture and purify CO2 to 99.5% purity to ensure the project is sequestration ready.


Proponent needs to further detail how it will ameliorate CO2 emissions to ensure that State and NationalCO2 targets can be met. Alternatively the proponent should be made to commit to bio sequestration aspart of its approval


Bio-sequestration will require significant quantities of land and water and will impose significantenvironmental impacts. It is Perdaman’s understanding that, as with the Lower Leseuer geo-sequestration project, the developers of this technology are still proving it. Perdaman has committedaround $400M in its project to ensuring that its CO2 production is sequester-ready when a suitabletechnology is proven.


The proponent should provide a summary of the various gasification technologies available with a view tothe modelled carbon emissions from each technology


Commercial gasifiers (ie proven at scale of over 500 tonnes/day) can be classified as:1. Slagging and non-slagging;2. Wet or Dry feed; and3. Heat recovery via quench or steam raising.

High efficiency, low emissions gasifiers such as that Perdaman will use operate at a minimum pressureof 30 barg. The gasifier carbon emissions can broadly be linked to degree of energy recovery over thegasifier, although it is noted that up and downstream process requirements also influence this.

Based on an analysis of Collie Coal, Perdaman decided to specify maximum heat recovery ingasification, as this would produce lowest CO2. The key design parameters for the Collie gasifiers are:

» Slagging design

» Shell/Uude process - dry feed, steam gen 80% Cold Gas Efficiency Design, ~15% steam recovery


Alternative gasification technologies achieve the following comparable results:

» Shell/Siemen/Uude - dry feed/quench design - 79% efficient, 11% steam

» GE/Conoco - slurry feed/quench design - 72% efficient, 14% steam

» Lurgi non slagging - dry feed/steam recovery design - 88% efficient, 4% steam. Lower gasificationtemperatures with this temperature lead to high selectivity to methane and tar production, which aresignificant disadvantages


What steps will be taken to manage the 3.2 Mt of CO2 emitted if geo-sequestration is not an option.


Perdaman is also investigating the use of bio-sequestration options, using algae. In relation to CO2emissions, more CO2 is bio-sequestered as a result of enhanced plant growth when urea is applied, thanis emitted when urea is manufactured. That is, the process is carbon emissions positive whenconsidering the product life cycle.

(180) South West Environment Centre (SWEC) Issue

The proposal does not provide any direct offsets for carbon emissions not does it consider or contributeto Federal Government targets for reduced GG emissions. The proposal provides no realisticsequestration means, targets, actual or aspirational for carbon pollution reduction.

Proponents Response to SWEC Issue

Perdaman has sought to minimise greenhouse gas emissions through careful selection of technology onthe urea plant, as detailed in Table 47 in the PER. Perdaman’s offsets strategy is outlined in Table 48 inthe PER. Until the various sequestration technology options are commercially proven, Perdaman cannotmake binding commitments. In relation to CO2 emissions, it is important to note that more CO2 is bio-sequestered as a result of enhanced plant growth when urea is applied, than is emitted when urea ismanufactured. That is, the process is carbon emission positive when considering the product life cycle.

6.2 Noise (70) SWIM Issue

Environmental modelling of noise emissions should be expanded to include alternate modelling in linewith best practice for understanding industrial noise emission


The noise assessment studies have been reviewed by the DEC Noise Branch and it has not raised anyissues with the methodologies used in the assessment.

(71) SWIM Issue

Noise modelling should also include impact on transport routes



Noise prediction was undertaken for the primary transport route being rail transport to Bunbury (Section8.3.3 of the PER). As detailed in the PER, increased vehicle traffic volumes associated with the operationof the plant are not expected to be significant and as such, no modelling of road transport wasundertaken. The noise assessment studies have been reviewed by the DEC’s Noise Branch and it hasnot raised any issues with the scope of the assessment in relation to transport noise.

(108) Shire of Collie (SoC) Issue

Noise criteria is to tie in with the proposed Local Planning Scheme No 5 Amendment No.1. The noisemonitoring and management plan be required to verify noise predictions and develop a method ofhandling complaints and reporting thereof.

Proponents Response to SoC Issue

It is Perdaman's understanding that Perdaman's obligations in relation to compliance with noiseregulations at sensitive receptors are independent of any Local Planning Scheme requirements aroundbuffers. Nonetheless, Perdaman has met Collie Shire and LandCorp, who is responsible for s48approvals in relation to the Scheme amendment, to discuss proposed buffer zone arrangements for theproposed Shotts Industrial Estate. The only current sensitive noise receptor within the proposed buffer isthe Collie Motorplex Caretaker's cottage and Perdaman is prepared to implement practical measures tomitigate noise at this receptor.

Perdaman is maintaining ongoing discussions with both the Shire and LandCorp in relation to the LocalPlanning Scheme Amendment.

As part of Part V approvals and licensing conditions, Perdaman will develop an EnvironmentalManagement Plan which will address monitoring, reporting and control actions with regards to noisemanagement.

(116) DEC Noise Branch Issue

Non-compliance at the Stockton Lake caretaker's cottage. The PER should consider options forrelocation or other solutions to this noise non-compliance issue; and ii) that this issue be addressed andresolved with the appropriate authorities before the project is approved

Proponents Response to DEC Noise Branch Issue

Subject to revised noise modelling based on detailed design information, Perdaman will assess alloptions for mitigation of noise at the Caretaker's residence as required. Any such mitigation will beresolved with the appropriate authority.


Predicted high noise level at Stockton Lake. The noise branch would reiterate their recommendation thatthe proponent work with the Shire and local community to develop an appropriate aspirational goal fornoise emissions for Lake Stockton.


(129) RAG Issue

The PER dismisses the value of Stockton Lake (Section 8.3.1) "Stockton Pool (sic) does not warrantspecial protection from noise as natural quiet is not part of the intrinsic value of this place".

Proponents Response to DEC Noise Branch and RAG Issues

Perdaman has committed to working with Collie Shire in addressing noise management relative toStockton Lake.


The Noise branch requests that the proponent demonstrate how practicable the overall noise power levelof the proposed urea plant can be reduced to 116 dB(A), or at least 120 dB(A).


Noise modelling undertaken for the PER was very conservative to ensure noise levels were notunderestimated. This was based on preliminary design information available at the time the PER wasprepared. As part of the next stage of design, Perdaman has required all suppliers to provide detailedspecifications including sound power levels and attenuation measures. Based on this information and thedetailed design layouts, Perdaman will re-model noise from the plant and is confident that a significantreduction in overall noise levels will be achieved. A copy of the revised noise emissions modelling reportwill be made available to DEC Noise Branch when it is ready.


7dB noise reduction requirement for Bunbury Port Operations. Because the 7dB noise reduction isnormally considered a goal that is difficult to achieve for such as large port operation, the Noise Branchwould recommend that the proponent adopt all the noise control measures proposed by LGA for theconveyor. The proponent must do more than 'investigate installing balanced and machined idlers on theconveyor'


Perdaman has committed to undertaking all the noise control measures proposed in the LGA BunburyPort Noise Assessment.

(120) RAG Issue

Identification of Sensitive receptors being determined from aerial photographs is not adequate.Consistency of sensitive receivers required for Air quality and Noise reports. Review noise impactresults and clarify as they are based on the wrong receptors. Night time values are for the wrongreceptors.


Sensitive receptors were located from an aerial photograph and also based on previous and currentassessments. Use of this information was requested by DEC to maintain consistency with previousmodelling done in the area.


An error in labelling of receptors near Cardiff was included in the receptor location tables and resulted intwo of the receptor locations being mislabled. The levels reported at each receptor however are correct.The location of the background noise monitoring site was also correctly identified.

The modelled outcomes at the balance of sensitive receptors at Cardiff and Collie Burn still demonstratecompliance to noise regulations at these sensitive receptors. The above labelling error does not alter theconclusions of the noise assessment.

(121) RAG Issue

Increases in noise at Cardiff and Collie Burn at 27 dB and 35 dB is a significant increase


The proposed modelling demonstrates compliance with the noise regulations. A typical comparison of 35dB is the level of sound in a library. Whilst increases in noise levels are predicted, these are off anextremely low base. The overall impact is not considered significant.

(122) RAG Issue

The Canadian OHS website gives information about the decibel scalehttp://www.ccohs.ca/oshanswers/phys agents/noise basic.html Table 3 states that a 3dB increasedoubles the noise, a 10 decibel increase is a 10 fold increase in noise and a 20B increase is a 100-foldincrease in noise. Night time noise levels for Cardiff are predicted to increase by at least 6-8dB andCollie Burn by at least 9 to 16dB (see above). For Cardiff this is a four to eight-fold noise increase and forCollie Burn this is a 10 to 32-fold noise increase - from near the limit of measurement to the maximumnight time prescribed level.


The proposed modelling demonstrates compliance with the noise regulations. Whilst increases in noiselevels are predicted, these are off an extremely low base. A comparison of 35 dB is often given as thenoise experienced in a library. The detectable noise difference is not considered significant.

(124) RAG Issue

That PCF models the noise for Cardiff and Collie Burn under calm/light wind and temperature inversionconditions.


The worst case meteorological conditions already used in modelling represent calm/light wind andtemperature inversion conditions.

(127) RAG Issue

Inadequately addresses noise emanating from the construction of the waste water pipeline and notconstruction of the plant itself. A full impact of assessment of noise from construction of the Shotts plantshould be modelled and discussed.

http://www.ccohs.ca/oshanswers/phys



As detailed in the PER, construction noise associated with an above ground pipeline would only involvedequipment which may typically be found in an urban construction setting (grades, excavators etc.) and berestricted to daylight hours. An assessment of the water supply pipeline was undertaken given theproximity of the alignment to a number of residences. Neither the wastewater pipeline or coal conveyorare in proximity to any sensitive receptors and both are adjacent to working mine sites. On this basis, anassessment of construction noise impacts on these activities was not warranted.

Construction noise from the plant site will be limited to typical construction equipment and noises. Thereis no blasting expected. Construction activity will primarily be restricted to daylight hours, however theremay be times during plant fit-out where night-time work is required. This work is not expected to beactivities which will create excessive noise. Given the buffer distances to sensitive receivers, noisemodelling for construction activity is not considered to be significant and was not requested by the EPA.

The noise assessment studies have been reviewed by the DEC’ Noise Branch and they have not raisedissue with the scope of assessment presented in the PER.

(128) RAG Issue

RAG believes that noise levels at Stockton Lake of 50 dB, triple the noise level at which it is not possiblefor the average person to sleep (45 dB), are unacceptable.


Perdaman has agreed to work with the Shire of Collie in addressing noise at Stockton Lake. Perdamanexpects that further modelling based on a more detailed understanding of the actual design for the plantsince previous modelling will show a reduction in noise levels from that presented in the PER.

(131) Rural Action Group

Perdaman proposes a target noise level of 65dB at the urea plant boundary (Section 8 .3.1). It does notsay whether this is LA10 or LAmax. To propose a target based on achievable levels is unacceptable.Noise limits should be decided in advance for any land used as an industrial site and based onminimizing loss of amenity to residents. RAG understands other industrial sites in Collie (such asCoolangatta) have limits of 35dB at their boundary.


The 65 dD target is derived from the baseline assigned noise levels for Industrial Facilities detailed in theEnvironmental Protection (Noise) Regulations 1997 as presented in Table 51 of the PER. The noise levelrefers to LA10.

(132) Rural Action Group

RAG believes the noise levels emitted by PCF should follow the EPA's industrial estate guidance(http://www. epa.wa . gov.au/docs/2495 GS8.pdf) Section 3.2.1 Cumulative Noise) and be below 5dBless than the normally prescribed level at any receiving premises.



Noise emissions will need to meet all the established guidelines all of the time. These should be reportedto the community on a quarterly basis through the local press.

Proponents Response to Glyn Yates and RAG Issues

Perdaman is committed to meeting noise regulation requirements and the current proposal is compliantwith these regulations. Perdaman will regularly report to DEC regarding compliance with its licensingconditions.

6.3 Terrestrial Vegetation and Flora

6.3.1 Shotts Industrial Park

(18) SWIM Issue

Land clearing off sets have not been addressed in the PER both for the development of the Shotts site,extra clearing along the propose pipeline routes and for the land clearance required for the expansion forthe Muja coal mine site in relation to coal extraction for the PCF project.


Land clearing for the Shotts Industrial Park has been assessed separately by LandCorp as part of theapproval for the whole estate. Land clearing for the Muja mine is being assessed separately as part of aseparate approvals process. Clearing issues for the urea plant pipelines and conveyors has beenassessed and additional information provided in this Chapter 3 of this Supplementary report. Offsets willbe applied in relation to any clearing associated with the pipelines and conveyor.

(21) SWIM Issue

It is not unambiguously clear whether or not the environmental factor of vegetation forms part of thisassessment or if it will be assessed under the proposed amendment to the Collie Town PlanningScheme (Shotts Industrial Park)


Assessment of vegetation clearing within the Shotts Industrial Park is being formally assessed as part ofthe LandCorp Town Planning Scheme amendment. Information was included in the PER forcompleteness. Vegetation impacts associated with infrastructure located outside the proposed IndustrialPark is to be assessed as part of this PER. Further details are provided in Chapter 3 of thisSupplementary Report.


(22) SWIM Issue

There are significant inconsistencies between the stated scope and scale of disturbance to nativevegetation between the various documents describing the proposal, including the ESD and the PER, andwithin the PER itself


Information provided in the ESD is of preliminary nature only and was prepared earlier in the projectassessment. Information provide in the PER is the current estimate. Approvals under Part V of theEnvironmental Protection Act, including permits for vegetation clearing, will be based on layouts definedduring ongoing design for the facility.

(23) SWIM Issue

The level of detail pertaining to the clearing of and potential impacts to native vegetation for theinfrastructure corridors is not sufficiently defined to conduct a proper assessment and for complianceauditing purposes


Perdaman undertook additional spring survey of the infrastructure corridor alignments based on currentdesign information. Please refer to Chapter 3 of this Supplementary Report for additional information oninfrastructure corridors.

(25) SWIM Issue

The potential impact on biodiversity at the species and ecosystem levels has not been sufficientlydescribed. The EPA advises that the natural significance of species and communities is not limited totheir list status, but also applies to their local contexts and role in maintaining natural values andfunctions (eg EPA 2004, 2008a). Such aspects have not been presented in the PER. Without thisinformation it cannot be seen how a transparent assessment can be made by the EPA or the Minister forthe Environment


The potential impact of the proposal at the species level has been made. Vegetation complexes andspecies are well represented on a local and regional scale. Please refer to Section 3.

(26) SWIM Issue

There is no justification provided for the clearing requirement, i.e. there is no discussion of why theproposal cannot be constructed on previously cleared land, nor is any rationale provided for the size ofthe clearing footprint or those steps taken to avoid disturbing vegetation. This shortfall applies to both thesites and the infrastructure corridors.


Engineering and economic drivers in designing the plant layout will push to minimise the plant footprint toreduce costs associated with piping, conveyors, electricals and the extent of paved surface area. As


demonstrated in Figure 6 in Section 4, the plant has been positioned on the site to maximise the use ofexisting disturbed areas. The alignment of pipelines and conveyors were specifically chosen to minimiseimpacts and vegetation clearing. By utilising existing previously cleared or partially cleared easements,vegetation clearing will be kept to a minimum and will primarily involve regrowth vegetation.

(27) SWIM Issue

The PER makes no attempt to present information that would demonstrate to the EPA that the proposalwould not cause any association or community of indigenous plants and/or animals to cease to exist.This is particularly relevant in the Collie Basin, which is a unique and restricted landform and underpressure from a number of sources and processes including mining, salinity and groundwater (DoW2009)


The vegetation on the site is considered to be locally and regionally well represented (Matiske (2002).No PEC's or TEC's occur on the site. No Declared rare flora was identified as occurring on the site. Thehabitat of the site was not considered unique in the area and therefore not likely to cause "anyassociation or community of indigenous plants and/or animals to cease to exist.". Please refer to Section3.

(28) SWIM Issue

The PER presents no information to show whether or not the proposal would not compromise anyvegetation type by taking it below the 'threshold level' of 30% of the pre-clearing extent of the vegetationtype. Information in this regard in the relevant appendix (Appendix G) utilises the extremely coarse BeardVegetation Association, which is considered by the EPA (2006) and others (eg ESCAVI, 2003) as beingtoo coarse for assessing impacts on community representativeness.


The updated 2009 Flora report (Section 3 and Appendix D) discusses the vegetation extents based onthe RFA vegetation mapping by Mattiske and Havel (1998). There is no published compressive datasetof the vegetation extents in the RFA area (as there is for Beard) however there is a report on the PoorlyReserved Vegetation Complexes in the System 6 area (Mattiske, 2002). Of the poorly reservedvegetation complexes that occur in the study area, all of them have greater then 50% of their pre-European extent remaining (Mattiske, 2002).

(29) SWIM Issue

No verifiable information is provided by the proponent to verify its statement in the PER that vegetationon the site is "relatively similar to local native vegetation occurring in the surrounding region and wellrepresented locally and regionally" (p iv of Exec. Sum.).


The vegetation on the site is represented across the site and is represented on a regional scale byvegetation types mapped by Mattiske and Havel (1998). Examination of the Mattiske and Havelvegetation mapping on a local and regional scale identified the vegetation types as being wellrepresented on both a local and regional scale.


(30) SWIM Issue

No information has been provided by the proponent to demonstrate that there is comprehensive,adequate and secure representation of scarce or endangered habitats within the project area and/or inareas which are biologically comparable to the project area, protected in secure reserves.


There are no scarce or endangered habitats within the project area. Please refer to Section 3.

(31) SWIM Issue

Not all on-site and off-site impacts of the proposal have been identified as per EPA requirements,particularly those relating to clearing for corridors and secondary impacts from gaseous and otheremissions, and that it has not been demonstrated that these impacts can be managed.


Clearing requirements for off-site infrastructure has been identified in the PER and following additionalengineering input, greater definition of alignments and clearing is provided in Chapter 3 of thisSupplementary Report.

(32) SWIM Issue

The proponent has not presented any information on the potential impacts of the proposal on the existingbiodiversity conservation recommendations of the national frameworks to which Western Australia issignatory to. These include the Regional Forest Agreement and the WA Forest Management Plan, theNational Biodiversity Strategy and its Principles for Biodiversity Conservation


Biodiversity impacts have been discussed on a local and regional scale as detailed in Appendix D.

(33) SWIM Issue

The proponent has not presented any information describing how the proposal might affect the outcomesand recommendations of the national 2002 Biodiversity Audit (CALM, 2003), which was based on theIBRA units, the southern and central Jarrah Forrest units that surround the site


The Biodiversity audit provides an overview of all impacts in the Southern Jarrah Forest region. Thereport addresses impacts of the study area including, vegetation, flora, fauna , TEC's and PECs all ofwhich have been addressed in the Final Flora report (Appendix D).

(34) SWIM Issue

The proponent has not satisfied the requirements of the EPA in regards to the information and scope offield surveys of native vegetation and does not present sufficient information to address both biodiversityconservation and ecological function values of the site and its surrounds



Flora and Fauna Assessments for the Perdaman study area have been undertaken with reference toEPA Guidance Statements 51 and 56.

(35) SWIM Issue

The PER does not accurately and sufficiently present the findings of the vegetation surveyscommissioned by LandCorp and does not include all of the survey reports or data for analysis


Survey undertaken for LandCorp addressed the entire Shotts Industrial Park. The initial 2007 survey wasconsequently supplemented by other survey specific to the Perdaman site. Information relevant to thePerdaman site was summarised in the PER from the Shotts Industrial Park report. This information wasincluded for completeness as land clearing impacts are being addressed by LandCorp and assessed byEPA as a separate approval for the Shotts Industrial Park.

(36) SWIM Issue

In assessing the information presented in the PER against EPA Guidance Statement No. 10, thefollowing observations can be made: The Proposal lies within the Collie Basin, which is a unique andregionally restricted landform. No assessment of the adequacy of the Reserve System has yet beenundertaken for the Collie Basin and areas of Crown Land should not be cleared for industrial purposesuntil it has been demonstrated that such clearing will not impact on Regionally Significant Areas, as perGuidance No. 10.


Mattiske (2002) Reporting on the Poorly Reserved Vegetation complexes in the RFA. Four of theMattiske and Havel (1998) vegetation complexes that occur in the survey area are considered to bepoorly reserved however all four vegetation have more than 50% of the pre-European extent remaining.The Reservation of Crown Land in the Collie area is not relevant to the Perdaman’s PER.

(37) SWIM Issue

The survey effort for the wastewater pipeline, as reported in Appendix G, needs to be clarified to ensurethat the effort is suitable for the complexity of the survey area and that the timing of the survey wasappropriate.


In reviewing the Draft PER, the EPA recommended additional spring survey of the water supply pipelinecorridor. A survey was undertaken in October 2009 for the water supply, wastewater pipeline andconveyor alignment based on these recommendations. These results are presented in Chapter 3 of thisSupplementary Report.


(38) SWIM Issue

The proponent should provide its response to EPA feedback to its original 2007 flora survey of theproposal site, as well as making the survey available to the public.


The original 2007 survey was commissioned by LandCorp for a greater area of the Collie ShottsIndustrial Park. Perdaman is unaware of any response from the EPA regarding the 2007 report.

(39) SWIM Issue

The vegetation survey presented as a appendix to the PER does not identify or discuss the limitations ofthe survey, so falls short of the EPA expectations in regards to rigour of reporting


A limitations table has been included in the Final Flora report

(40) SWIM Issue

The surveys conducted do not extend outside of any potential impact areas, so the assessment of localand regional impacts, as committed to in the ESD and as required by EPA, cannot be reliably undertaken


The study area included significant areas of vegetation outside of the study area, including the waterpipeline route through Wellington National Park.

(41) SWIM Issue

The proponent has not collected any floristic data from standard quadrants, as per the GuidanceStatement, so comparison against previously described Priority Ecological Communities cannot be made


There are no previously described PEC's in the Collie area as such there is nothing to compareoutcomes with.

(42) SWIM Issue

The proponent has not addressed the native vegetation clearing principles of Schedule 5 of theEnvironmental Protection Act 1986 in the PER


The final flora report includes an assessment against the 10 Clearing principles.

(43) SWIM Issue

In addressing the information presented in the PER against DEC draft Policy Statement No. 9, thefollowing observations can be made: The absence of previously described Threatened Ecological


Communities (TEC) within or surrounding the proposal site does not automatically confer the absence ofsuch communities, as it is unlikely that the area has been previously surveyed to such a level.


We can only work with the knowledge as is available at the time of reporting. The DEC is not aware ofany TEC's or PEC's either locally or within the study area therefore the assumption is that no TEC's orPEC's occur within the study area.

(44) SWIM Issue

The PER contains no information on the local significance of the vegetation and flora of the proposal siteor other important ecosystem functions.


The local significance of the vegetation is addressed in the Flora report Appendix D.

(49) SWIM Issue

Proponent needs to detail how it will prevent a deleterious impact on surrounding areas from declaredplant species currently identified within the proposed Shotts Industrial Park due in part to furtherdisturbance of land and also the increased nutrient load that will arise from the plant emissions


As part of the Part V approvals for development of the site, a Weed Management Plan will be prepared,to the satisfaction of the Department of Environment and Conservation, to address site management andthe control of weeds specifically to prevent off-site impacts. Similarly, a Stormwater Management Planwill be prepared which will control all runoff from the site to ensure no unacceptable discharges offsite.


Additional clearing of land by Griffin for coal mining for PCF Feedstock.

Proponents Response to Anonymous Letter Issue

Assessment of additional clearing for Muja Mine is being assessed as part of a separate approvalapplication by the mining company.


Value of state forests for their soil conservation should not be overlooked.


Value of state forests for their protection of surface and groundwater quality should not be overlooked.


Value of state forests should not be overlooked for their capacity to Capture Carbon and produce a netoxygen gain.



Assessment of clearing for the Shotts Industrial Park is being assessed separately as part of theLandCorp application. No State Forest will be cleared as part of offsite infrastructure.


Clearing will add to weed infestation, disease infestation, disrupt wildlife corridors, affect groundwaterand contribute to the drying out of surrounding forest areas.


Impact of clearing on the land and its surrounds. Management Strategy (Table 25, p 132) will not protectthe fauna and we will lose flora biodiversity.


As part of the Part V approvals for the project, Perdaman will be preparing detailed waste, stormwater,weed management, dieback, flora and fauna management plans specifically to reduce or avoid offsiteimpacts as a result of development of the project. These plans will be developed to the satisfaction of theDepartment of Environment and Conservation.

(102) DEC Issue

The management proposed is inadequate from the clearing of native vegetation. i) That the proposedclearing plan and flora management plan provide for the maximum recovery of timber, seed, wholeplants and woody debris for use in revegetation and in fauna habitat recreation; and ii) that any planneddisposal of vegetation by burning be minimised. Where burning is required, a management procedureshould be submitted to the Chief Bush Fire Control Officer for the Shire of Collie and to DEC forapproval.

Proponents Response to DEC Issue

During preparation of Part V approvals and following further project design, Perdaman will work withDEC in developing a Clearing Plan and Flora Management Plan. The plans will address timber recovery,seed collection and recovery of whole plants and woody debris where possible and practicable for use inrevegetation and fauna habitat recreation. Burning of cleared vegetation will be minimised but if required,management plans will be developed with and submitted to the Chief Bush Fire Control Officer for theShire of Collie and to DEC for approval.

(110) Shire of Collie Issue

That commitments covering the clearing plan, noise monitoring and management plan, and plans relatingto stormwater management, weed management and waste management include the Shire of Collie asan advising agency.

Proponents Response to Shire of Collie Issue

Perdaman will commit to include the Shire of Collie as an advising agency in the formulation ofmanagement plans for the project.


(112) Forest Products Commission Issue

The PER incorrectly notes P. pinasta - The PER notes it to be P. radiata 4.5.3 pg 61

Proponents Response to FPC Issue

Noted


Clearing of the site should be undertaken in such a way to prevent any over clearing but should be donein such a way as to ensure the safety and security of the people and the plant is not compromised as aresult of regrowth and bushfires.


Clearing will be undertaken as set out in the future Part V approvals which will include the developmentof an Environmental Management Plan which will address vegetation management and bushfire risk.

(185) FoESWA Issue

Loss of embedded carbon and further loss of native forests and habitat is unacceptable.

Proponents Response to FoESWA Issue

Perdaman have put considerable effort to reduce clearing both within the Urea Plant site and alonginfrastructure corridors. This includes the siting of the plant on predominantly disturbed land and usingexisting easements. Any impacts will be addressed through rehabilitation offsets.

6.4 Fauna

(45) SWIM Issue

The proposal does not satisfy EPA Bulletin No.1 in that no biodiversity offsets are actually proposed, onlysuggested. The proponent needs to assess the residual impacts to biodiversity as per EPA guidance andidentify suitable offsets for those impacts that cannot be otherwise avoided or managed


Vegetation clearing for the Shotts Industrial Park and the requirements for offsets are considered as partof a separate assessment for the LandCorp application.

As detailed in Section 5.1, vegetation clearing for pipelines and conveyors is significantly reduced byusing existing easements which will significantly reduce clearing impacts. The use of the existing waterpipeline from Wellington Dam means no clearing is required within Wellington National Park. Anyclearing is proposed to be regrowth vegetation within existing, managed easements.

Should detailed design identify that clearing may be required, Perdaman would be willing to commit tofinancial support for or direct purchase and rehabilitation of foraging habitat offsets as per thearrangement DEWHA has discussed with the WA Department of Environment and Conservation.


(46) SWIM Issue

Proponent needs to specify how it intends to ameliorate any impact on breeding sites, commit to habitatpreservation and highlight any revegetation options available at the Shotts site or any other site disturbedby PCF's operations to both the Carnaby's and Baudin's black cockatoo's


Impacts and mitigation strategies which related to the Shotts Industrial Park are being assessedseparately as part of the LandCorp application.

Perdaman is currently working with the Department of Environment, Water, Heritage and the Arts indefining the extent of impacts associated with the off-site infrastructure corridors, particularly in relation tocockatoo habitat and breeding trees. The infrastructure corridors associated with pipelines andconveyors have been specifically chosen so as to minimise clearing requirements. Clearing is primarilyrestricted to regrowth vegetation within existing pipeline or transmission line easements. Assessment ofpotential cockatoo breeding trees within the proposed construction footprint has been undertaken and nobreeding trees have been identified, subject to the changes identified in Section 5.1.

Perdaman has committed to rehabilitation offsets where clearing of vegetation that may constituteforaging habitat occurs.

(47) SWIM Issue

Proponent should conduct a more thorough fauna survey not just at the Shotts site but along theproposed pipeline corridors


Flora and fauna surveys have been undertaken to the satisfaction of the EPA. Fauna impactsassociated with the Shotts Industrial Park are being addressed by LandCorp as part of their application.Given pipeline and conveyor corridors are being located within existing formerly cleared easementswhich are regularly maintained to control vegetation, fauna surveys were not required by EPA.

6.5 Water Supply and Management

(48) SWIM Issue

The Proponent needs to address any risk posed to downstream users of water streams including dairythat may be urea enriched

(50) SWIM Issue

Storm water management plans should be established and detailed prior to the PER being finalised, asurea and sulphur enriched run off could have a significant impact on the wetlands

(55) SWIM Issue

Water borne urea will flow through prime dairy country in the Lower Collie River Valley - what publichealth risk arises from this given recent events in China



The PER does not adequately address potential pollution of groundwater and surface water in relation toeither normal operating conditions or plausible accident scenario's, particularly with the emitting of 1400tof ammonia per annum.

Proponents Response to SWIM Issues

Stormwater management plans will be prepared in consultation with DEC as part of Part V approvals anddetailed design. All surface flows within the site will be fully contained, treated and reused wherepossible. It is not intended that stormwater will be discharged from the site.

DoW have stated in their PER submission that if the Perdaman proposal is approved, they are satisfiedthat construction and operation of the plant can be adequately regulated under Part IV and Part V of theEnvironmental Protect Act 1986 and will not result in impacts on local water resources.

(54) SWIM Issue

Proponent needs to predict what increased Urea concentrations will be in the Port region, KoombanaBay and Leschenault inlet water ways. Proponent needs to indicate how it will mitigate marine incursionsand manage longer term impacts


Granular urea particles are 2-4 mm in diameter. Perdaman’s urea will be handled in weather protectedsystems to prevent rainwater ingress and as such dust issues will not arise during materials handlingoperations. Any spillage that occurs as a result of equipment failure during shiploading or rail transportwill be promptly cleaned up using dry vacuum or mechanical means, to prevent release to the Portmarine environment.

(63) SWIM Issue

The LWMS should be made available for public review prior to being submitted for approval bygovernment agencies


The Local Water Management Strategy (LWMS) is not a requirement of the PER. PCF will submit aLWMS to DoW for approval and it can undertake public consultation if it wishes.

Water

(64) SWIM Issue

The proponent should include in the LWMS a salt-volume balance for the saline discharge, that is, themaximisation of water re-use and recycling before ocean pipeline discharge criteria for salt are reached


Perdaman is agreeable to this, as it has already adopted this approach to the design of its waterprocesses on the plant. The limiting factor on discharge though is metals levels and not salt and this iswhat will place constraints on the extent to which Perdaman can maximise reuse and recycling. Thesemetals are already present in the raw surface water and are not added by Perdaman.


Water

(67) SWIM Issue

Proponent has not provided modelling of the marine impact of the increased saline outfall on newdevelopments on the coast at Binningup


Verve Energy has currently in preparation an environmental assessment for disposal of 3.6 Ml/day (~1.3GL year) of secondary treated wastewater from the Kemerton Wastewater Treatment Plant via the Verveocean outfall. Modelling used in this report includes an assessment of impacts from industrial dischargeof the nature proposed by Perdaman.

Perdaman is proposing disposal of 3 ML/day of saline water subject to water feed salt content. TheVerve report will be submitted by Verve to the WA EPA as part of a proposed licence amendment. Thereport includes a detailed assessment of potential marine impacts from the proposal includingmonitoring, habitat mapping and hydrodynamic modelling.

The Verve Energy report is not currently a public document. The following is summarised from thisreport.

Ground-truthing of marine habitats was undertaken in 2006, 2007 and 2008. A towed underwater videosystem was used to determine benthic habitat types. The area immediately surrounding the diffuser wasgenerally low relief pavement reef. The habitat surrounding the diffuser was spatially heterogeneous withhabitats of seagrass, sand and reef. Generally the reef was low relief reef which consisted of limestonecovered with a thin layer of sand and algae. The presence of algae was the factor that differentiatedbetween sand and low relief reef. There was also a smaller section of high relief reef to the south of theoutfall. This limestone reef was raised from the ocean floor and appeared to support various invertebratespecies as well as algae. Seagrass was generally not found within 600 m of the shore although therewere some small patches. Seagrass meadows were observed to generally be sparse throughout thearea.

There have been two studies of the Koombana Bay region and waters offshore, containing extensivesurveys of the local marine fauna (Walker 1979; Le Provost et al. 1983). These provide a good indicationof the species of fish, crustacea, other benthic invertebrate fauna and marine mammals likely to be foundin the region. It was found that the areas containing the greatest diversity and most important breedinglocations were the estuarine waters of the Leschenault Inlet and the Collie River.

The waters of Koombana Bay and Geographe Bay support a large variety of fish, including commerciallytargeted species such as: whitebait, salmon, herring, scaly mackerel, pilchards and shark. The fishoffshore largely consist of pelagic, migratory fish or reef fish. Bottlenose dolphins are common in theregion, remaining in Koombana Bay and surrounds all year round and humpback whales (Megapteranovaeangliae) migrate south along the coast towards Antarctica in spring. The whales and dolphins formthe basis for a valuable and growing local tourism industry. Australian sealions are also occasionallyseen in the region.

The region is home to large numbers of crustacea, including: Blue swimmer crab (Portunus pelagicus),rock lobster (Panulirus cygnus and Jasus novaehollandia), xanthidae, sponge crabs and snappingshrimp. The Blue swimmer crab and lobster have commercial significance.


LeProvost et al (1983) found 17 species of gastropod molluscs, 16 species of bivalve molluscs, threespecies of amphineuran molluscs, five species of sea urchins, 16 species of brittle stars, 17 species ofseastars, two species of feather stars, one species of lamp shell and six species of corals in the northernpart of Geographe Bay. They found no patterns on the distribution of these fauna relative to distancefrom shore or water depth. The rich diversity of the fauna reflects the mixture of limestone reef and sandhabitats, however, the species recorded were common to the south-west coast of Australia.

Maunsell (2008) carried out a literature review on fish in the area surrounding the proposed SouthernSeawater Desalination Plant (SSDP) for the Water Corporation. Limited information was available onspecific fish fauna assemblages in the area surrounding the SSDP (Maunsell 2008); however,information was available for the nearby Geographe Bay Region. Similar assemblages of fish speciesare found throughout most of the southwest of WA, with the Geographe Bay and Cape Leeuwin regionsbeing dominated by warm temperate species (76%), several subtropical species (19%) and a few tropicalspecies (5%) (Maunsell 2008).

One survey that sampled fish species in the seagrass beds between Capel and Dunsborough found that52% of all fish fauna caught were whiting species (Maunsell 2008). Given the dominance of seagrassbeds in this area, it can be assumed that the area would support a high abundance of fish fauna andother marine organisms. The area surrounding the proposed pipeline is unlikely to support uniquecommunities of marine fauna as seagrass beds are well represented in the southwest.

The Verve report modelled the mixing and dispersion of the existing and proposed discharges from theoutfall. The modelling was undertaken using four independent, yet integrated stages.

1. The hydrodynamics of the receiving waters was modelled using a three-dimensional barotropic (tidesand winds) circulation model, BFHYDRO and forced and validated with the Bunbury WWTP wind andcurrent data.

2. A near-field discharge model (UM3) was used to determine the near-field mixing (initial dilution) anddispersion of the wastewater based on the proposed diffuser configuration.

3. The generated currents and near-field mixing estimates were used as input into the pollutanttransport model, BFMASS, to predict the time-varying far-field mixing and dispersion and decay oftotal nitrogen (TN), enterococci and thermotolerant coliforms (TTC). The time varying die off rates forTTC were included in the model.

4. Concentration exceedance contours were calculated to show the median concentrations for thesimulation period.

Based the work done for the Verve project and experience on other ocean outfalls, the Verve reportmade the following general conclusions as they relate to addition of a new wastewater stream such asthat proposed by Perdaman:

» Based on the measured Verve concentrations, the EPA’s High Ecological Protection criteria for thesewill be met after initial dilution at the outfall.

» The salinity difference between the fresher wastewater and the ocean will be rapidly diminished andthe EPA salinity criteria will generally be met after initial dilution.

» Salinity is the only common factor of concern through which the Verve outfall and the adjacentMillenium Inorganic Chemicals outfalls may influence each other and create a cumulative effect


through the potential for two fresher surface plumes to mingle. The modelling demonstrates thatinteraction between the plumes from the two outfalls will not be an issue.

» The suggested size of the mixing zone (as defined by Low Ecological Protection Area) is at all points100 m distant from the diffuser.

The above investigations would indicate that there are no significant marine or habitat risks associatedwith the proposed discharge of saline waters from the Perdaman urea plant. The area of effect from theoutfall for a similar volume but more hazardous wastewater stream from the Kemerton WWTP is within100 m of the ocean outfall diffusers.

(68) SWIM Issue

The proponent should revisit the PER in light of the Upper Collie Water Allocation Plan (DoW - Aug2009) and again review the proposed location as an alternate location may provide more secure accessto the….(Incomplete in the submission)


The Department of Water has confirmed in its PER response that the Perdaman water managementstrategy is consistent with the Upper Collie Water Allocation Plan.

(69) SWIM Issue

Proponent should detail where the off take from Wellington dam will be situated and how this will impacton overall salt levels in conjunction with the DoW sourcing process


Agreement in principle has been reached with Water Corporation to enable Perdaman to access theexisting Wellington Dam off-take and pipeline to supply water to the site. This avoids the need toconstruct a new dam off-take and/or pipeline from the dam and the associated existing corridordisturbance activity, but a new 7 km pipeline will still have to be constructed from the Shotts IndustrialSite to connect to the existing pipeline, as per details provided in the PER report.

Desalination of 12 GL pa of water from Wellington Dam by Perdaman will remove approximately 34,200kg of salt from the dam per day, based on a salinity of 940 mg/l.


Impact of mining and abstraction on groundwater


Issues associated with mining activities will be addressed by separate approvals for any miningproposals. Perdaman will not be using groundwater as a water source for this project.



Runoff may become contaminated by hydrocarbons and may contaminate receiving bodies. Clearing willresult in sediment runoff.


As part of the Part V approvals for the project, Perdaman will be preparing detailed Sediment andErosion Control Plans for the construction phase and Stormwater Management Plans for the site. Thelatter will address containment and treatment of any potentially contaminated stormwater. Reuse of thiswater will be a key aspect of water management on the site. Discharge of untreated stormwater from thesite will not occur as part of this plan.


The amount of water stated in the letter of advice to PCF does not state 12 GL, rather that amount ofwater is provided from a range of sources. The uncertainty of supply sources and the contingencyoptions if there is a series of dry years is concerning, especially if potable water is to be purchased,which will also be scarce in a dry year.


The Department of Water has advised that it has assigned Perdaman 12 GL/yr (on the basis ofunallocated availability) of raw water, which can be sourced reliably from a centralised water supplyfacility (or water utility), with backup from Wellington Dam and further, that 12 GL/yr is available forallocation from the Wellington Reservoir. The Upper Collie Water Allocation Plan has evaluated theimpact of further allocations from the reservoir and that a 12 GL allocation would not pose an undue riskto surface water resources or to the environment.

An assignment is not a license to extract water from the environment though and Perdaman hastherefore applied for a 5C Surface water extraction license. Perdaman is currently in discussions withthe Department of Water in relation to the terms of the license, which may incorporate Perdamanextracting up to 6 GL pa of a 12 GL pa license allocation from the East Collie River salinity diversionscheme.

Refer also to Perdaman’s response to issue 147 below.

(109) Shire of Collie Issue

That an Urban Water Management Plan is identified as a requirement in the proposed Local PlanningScheme No 5 Amendment No.1 and that some existing commitments can be dealt with through that plan

Proponents Response SoC Issue

Noted. Perdaman will work with the Shire of Collie in the development of management plans for theproject.


(147) RAG Issue

Contingency for water use not clear if there are dry years, given that the operations are reliant on surfacewater.

Proponents Response RAG Issue

The Department of Water has indicated to Perdaman that groundwater is fully allocated and that onlysurface water resources are available of the quantity required for the project. The Collie urea project willnot use more than 12 Gl pa of water from Wellington Dam but Perdaman is in discussions with HarveyWater in relation to the use of up to 4 GL pa from its 68 Gl pa allocation in years where allocations arereduced due to drought. If Perdaman's allocation from the Collie basin is reduced to less than 8 GL inany year it will have to reduce its production to align with the available water allocation. If it becomesapparent that longer term reductions in water allocations become necessary, Perdaman will have toidentify and seek licensing to extract water from sources outside the Collie basin. This approach is ineffect the same that the Water Corporation uses to meet potable water demands from customers on itsnetwork.

(148) RAG Issue

No mention is made in Section 3.4.7 of replacing salt water taken from the Collie Basin with fresh wateris made. That an amendment is also made to the PER based on the advice from the DoW that PCF willtake up to 6 GL from the East Colle Diversion scheme such that there is no adverse impact on the riverecology or amenity.


Perdaman is seeking a license and approval to remove water from the environment and in the process iscommitting to improving the quality of water remaining in Wellington Dam for other users, by removingsalt from the Collie basin.

(149) RAG Issue

RAG would prefer that dry cooling is used. The arguments put forward by PCF against dry cooling arenot totally logical. The submission puts forward three arguments in favour of dry cooling.


Refer to Section 4 of this Supplementary Report for a detailed review of cooling water options.

(150) RAG Issue

It is ironic that the much lauded "carbon capture ready, clean coal technology" geo-sequestrationtechnology mentioned in the PER will require the transportation of carbon dioxide about the samedistance or further. This will obviously cost far more than pumping water and has less direct benefit to theproponent. Does it not follow then that even if geo-sequestration is ever proven possible, thetransportation of carbon dioxide gas for geo-sequestration will also be dismissed as too expensive byPCF?



The statement by RAG that the pumping of CO2 will cost more than the pumping of water is incorrect.The quantity of CO2 that would be pumped down the Darling Escarpment to the geo-sequestration site isabout 35% of the quantity of water that would be pumped up the Darling Escarpment if 12 GL pa of wateris extracted from Wellington Dam, so the quantities of CO2 to be transported are significantly less. Ofgreater significance though is the difference in pumping energy costs. The costs of pumping CO2 downthe Darling escarpment from the Collie Urea plant site to the lower elevation Lower Lesueur site aremuch lower than the costs of pumping water up from Wellington Dam to the top of the Darlingescarpment and thereafter to the project site.

(153) RAG Issue

How will PCF ensure that the waste water storage does not leach or overflow into either groundwater orStockton Lake.


The design and construction of storage ponds will use proven methods. Ponds will be lined withimpervious material and the design will include monitoring equipment to detect any leakage. Bestpractice design will be used.


If appropriate the use of void WO5H is possible. Verve currently use a proportion of this recharge forprocess purposes. Detailed discussions would be required before this could occur.


Perdaman has indicated a willingness to take up to 6 GL pa of its water license allocation from any EastCollie River salinity diversion scheme that is implemented by the Department of Water. It is understoodthat this water would be diverted during the early winter flows, when salinity is highest. As Perdamancannot store such a large quantity of water, it will be essential that the water be licensed to Perdaman forextraction from a suitable storage such as the 5H mine void and DoW has acknowledged that it will haveto establish some form of storage for the diversion water.


Water is not to be drawn from the Collie Basin as this needs to recover as it is over depleted.

Proponents Response Glyn Yates Issue

No groundwater extraction is proposed as part of this project. The Department of Water is seeking acommitment from Perdaman to take some of its water from the East Collie River salinity diversion andthis will be situated in the Collie basin.

(179) South West Environment Centre Issue

The PCF does not meet the essential water resource management to reduce, reuse and recycle.


Proponents Response SWEC Issue

PCF strongly disagrees with this statement. The PCF water treatment process will recover and recycle90 - 96% (depending on raw water source) of all water that is recoverable on the plant. This does notinclude water that is evaporated in cooling towers, as this water cannot be recovered.

(181) South West Environment Centre Issue

SWEC notes that nowhere in the PER does the proponent attempt to reduce its water use from 12 L perannum. SWEC maintains that this could be achieved by using dry cooling methods or hybrid coolingsystems, potentially reducing water consumption by a minimum of 50%

Proponents Response SWEC Issue

Refer to Chapter 4 of this Supplementary Report.

(183) FoESWA Issue

Ocean outfall should not be considered. 12GL is excessive. Salinity and contamination qualityconversion will increase energy use resulting in further emissions.

Proponents Response FoESWA Issue

The Department of Water has advised that 12 Gl pa of (saline) water is available from surface watersources in the region. Perdaman has chosen lower emissions and water use gas turbine technology tosupply power to the water treatment plant. The emissions contribution to the Collie airshed from the ureaplant is very small and the emissions associated with power supply to the water treatment plant are onlyabout 2% of overall plant emissions.

(189) Department of Water Issue

The PER omits to consider dry cooling as a possible technology. This needs to be addressed.

Proponents Response DoW Issue

Refer to Chapter 4 of this Supplementary Report.


The DoW will assist the proponent to develop a comprehensive water management strategy as acondition of any s.5c licence.


Perdaman will seek assistance from DoW in developing a comprehensive water Management Strategyas part of Part V approvals.



An urban water management plan is expected to be a condition of approval for the project.


Perdaman acknowledge that a Urban Water Management Plan will be a requirement of projectapprovals.


DoW does not support the storage of wastewater on site. DoW expects that the treatment and disposalof wastewater from the project's operations will be given a high degree of scrutiny by the EPA.


Numerous stormwater storage ponds already exist in the adjacent coal mines. It will be necessary forPerdaman to install impervious lined ponds to provide the capacity to store saline brine prior to dischargeto the Verve outfall pipeline. The reasons are firstly, that Verve requires the wastewater to be batchtested for compliance with license conditions prior to discharge and to do this Perdaman must store thewastewater. Secondly, in the event that the Verve outfall pipeline is unavailable for a period for repairs,Perdaman must store wastewater on site to enable continuity of operation of the urea plant during anyoutfall pipeline outage. The wastewater ponds will be continuously monitored for leakage and remedialaction will be taken if any leakage is detected.

6.6 Waste

(10) SWIM Issue

Proponent should provide information on emission and waste volumes whilst plant is in unstableoperation

Proponents Response SWIM Issue

In the upset conditions all the waste emissions will be flared. All liquid effluents will be treated in thewaste water treatment plant. No additional waste streams are anticipated to be generated during periodsof unstable operation.

(12) SWIM Issue

The PER has not specifically addressed how waste material will be managed or disposed of nor does thePER address ancillary issues associated with land clearing for storage of wastes or transportationissues.


Table 73 and Table 74 in the PER report clearly identify the quantity and type of wastes and defines themethodology of disposal. In general, waste will be reused or recycled wherever possible but whereresidual waste streams have to go to landfill, they will be conveyed to third party licensed landfill


operations in accordance with regulations. The quantities involved will not significantly add to wasteflows into landfill operations in the south-west.

(17) SWIM Issue

The proponent should detail how the caustic effluent will be transported to the Shotts site, or if anotherpipeline will be required to take the CO2 to the alumina producers. Further the proponent should detailthe process of mineralisation, the quantity of effluent and the ratio of CO2 to effluent, and finally thedisposal mechanism for the final product including transport implications


There will be no transport of caustic effluent to the Shotts site from the Alumina producers. Apressurised CO2 pipeline would be constructed to transport CO2 from the Urea plant site to the Aluminaproducers for use in mineralisation, if the application is proven technically, environmentally andcommercially feasible in due course.

(24) SWIM Issue

There is no specific plan to dispose of coal wastes (slag) generated as a by-product from the process


Details on slag volumes and disposal options are detailed in Table 62 page 225 and also Table 4 page38 of the PER report. If a buyer can be found for the slag in the road construction industry it will be soldand if not, Perdaman proposes to pursue the option of burying the slag at the Griffin mine. The slag isnon-leaching and approval for this is addressed in the Griffin Muja South PER.

(56) SWIM Issue

Additional overburden, coal waste and slag will also arise from the questions surrounding the massbalance. The proponent needs to address all these issues fully in the PER as mine clearance


Perdaman will manage and dispose of waste in an appropriate manner as detailed in Tables 73 and 74of the PER.

(57) SWIM Issue

The critical solid waste management of Mercury is not specifically addressed in the PER


Mercury is captured in Mercury guard beds installed in the process. The spent adsorbant will be returnedback to the manufacturers for regeneration/reuse.


(62) SWIM Issue

The proponent should specify how it plans to store any slag from the operation with particular emphasison dust suppression. Also no impact on transport for this material has been included in the PER. If theslag is to be stored or retained longer term on site then the PER should cover the rehabilitation plan forany slag piles that may be left


As stated in the PER, the slag will be sold or conveyed to the mines for backfilling. An area in the sitehas been marked for temporary storage. The slag is not dry, and hence dusting issues won't arise. Dustsuppression systems will be engineered at the temporary receiving areas and handling areas in theplant.

(65d) SWIM Issue

What method will be employed to combine fly ash and concentrated brine


Perdaman has not yet undertaken any detailed engineering design, but the likely design will involve theuse of a pugmill mixer, similar to that which Griffin Energy uses to slurry flyash at its Bluewaters Powerstation. Cement would also be added to the mix to bind the mixture if necessary.

(65e) SWIM Issue

What method will be employed to further stabilise brine/fly ash


The waste management processes that are generally employed comprise mixing of cement, flyash andliquid waste, a process that is referred to as chemical fixation and stabilisation (CFS). Treatment will beundertaken in accordance with Landfill Waste classification and Waste Definitions 1996 (As amended), adocument published by the Department of Environment and Conservation.

(66) SWIM Issue

Proponent also needs to detail what quantity of fly ash will be required to trap concentrated brine,quantity of truck movements for both inbound fly ash and outbund stabilised solid waste


In principle agreement has been reached in relation to access to the Verve Energy pipeline for disposalof 3 ML/day of wastewater in accordance with the existing DEC license. The extent of any residual wastethat may require brine concentration, fixation and solid waste disposal is dependent on a decision by theDepartment of Water in relation to licensing of raw water from the East Collie River diversion. Thegreater the proportion of raw water DoW requires Perdaman to take from the East Collie River relative toWellington Dam, the greater the quantity of wastewater produced, due to the higher salinity in East CollieRiver. Quantities of flyash cannot be estimated yet, but any flyash requirements will be met by overlandtransfer from the Griffin Mine and not by public road.


6.6.1 Wastewater

(65) SWIM Issue

The proponent needs to more clearly state how they will manage the saline outfall in the event of asignificant down time period of the Verve pipeline.

(65a) SWIM Issue

How large will initial settling ponds be?

Proponents Response SWIM Issues

As is stated in Section 9.6.1 of the PER report, Perdaman proposes to construct 2 x 21 ML capacityimpervious lined ponds to provide buffer wastewater storage against downtime on the Verve pipeline.This is nominally two weeks of storage capacity and is expected to provide coverage against most if notall circumstances where the pipeline is unavailable. If the pipeline is unavailable for longer periods thePerdaman plant will shut down.

(65b) SWIM Issue

What time frame before brine concentrator is operable after a shut down period?


Perdaman's nominated supplier advises that a maximum of 6 hours would be required to start up a brineconcentrator after a shut down period.

(65c) SWIM Issue

What size will the settling ponds for the concentrated brine be, will they be lined/covered?


The ponds will be constructed to comply with Australian Standards and will be fully lined with animpermeable membrane as stated in Section 9.6.1 of the PER.


The Verve waste water pipeline is not adequate and already has leakage problems. Option 2 of the minevoids is not adequate and not appropriate rehabilitation, what about the impact of salts that may leachinto the groundwater.


The existing pipeline is currently being re-sleeved to address issues with leakage. It has adequateunused capacity to service the Collie Urea project. The ponds will be constructed to comply withAustralian Standards and will be fully lined with an impermeable membrane as stated in Section 9.6.1 ofthe PER.


6.7 Risk Assessment and Management (72) SWIM Issue

It is prudent that an operation of this scope in relative proximity to a significant community (Collie andsurrounds) warrants the development of a full Health Impact Statement

(73) SWIM Issue

Could the proponent increase the number of ammonia storage vessels and thus reduce the magnitude ofany emergency events and therefore public risk

Proponents Response to SWIM Issues

This is not part of the PER approval process and will be dealt with in Major Hazard Facility licensingprocesses with the Department of Minerals and Petroleum. A detailed Risk Assessment will be carriedout for the site, and outcomes from that will be guiding the engineering decisions. In a typical set up of anammonia-urea plant, the entire ammonia produced is consumed captively by the urea plant and thusammonia tank levels are maintained as low as possible. During operational phase of the plant,procedural controls will be in put in place to ramp down ammonia plant in case of a prolonged urea plantshutdown. The Risk assessment has considered 10,000 tonnes of inventory as a conservativeassumption.

(74) SWIM Issue

Why has the risk assessment failed to consider sub-lethal, i.e. chronic risks that might arise from a'cocktail' of potentially toxic emissions in an already overloaded airshed

(139) RAG Issue

Concerned that may be a risk to the community from long term ammonia emissions

(156) RAG Issue

RAG has serious concerns regarding the scope, nature of and data used in the risk assessment providedin the PER by PCF. The 'affected' population is grossly underestimated. RAG urges that an Independentrisk assessment is undertaken accounting for the matters raised in the RAG submission.

Proponents Response to SWIM and RAG Issues

The preliminary risk assessment undertaken in association with and made public in the PER onlyconsidered the risk of fatalities, because more comprehensive risk assessment studies will beundertaken as part of MHF approval processes and community health risk assessment will be addressedin Town Planning Scheme Development Approval processes. A comprehensive risk assessment is notrequired for PER approval processes.

Ammonia is not considered to have any long term chronic effects. Ammonia is naturally occurring in theatmosphere as well as a man made chemical. Ammonia is an essential element for plant, animal andhuman life. It is found in water, soil and air, and is a source of much needed nitrogen for plants andanimals. Most of the ammonia in the environment comes from the natural breakdown of manure, deadplants and animals. Though ammonia is classified as a toxic substance at elevated concentrations, it isnot known to have any long term effects. This can be confirmed by information available on internet andother published literature. This is also reinforced by the fact that it has a threshold exposure limit of 25


ppm which is above the concentration that can be observed in a modern ammonia plant. Normalammonia emission levels in a properly designed modern ammonia plant are only fugitive in nature andare normally well below the odour threshold.

Permissible levels of exposure to toxic gases are defined by time-weighted average (TWA), short-termexposure limit (STEL), and concentration at which toxic gases are immediately dangerous to life orhealth (IDLH). The TWA is defined as the concentration for an 8-hour workday of a 40-hour workweekthat nearly all workers can be exposed to without adverse effects. Similarly, the STEL is theconcentration to which an exposure of longer than 15 minutes which should not be repeated more thanfour times per day.

Anhydrous ammonia has a TWA of 25 ppm, an STEL of 35 ppm, and an IDLH of 300 ppm

(75) SWIM Issue

The assessment of Ammonia risk should be based on World's best practice limits as indicated by the USEPA limits


An extensive literature review of the toxicity effects of ammonia was undertaken as a part of the riskassessment process. The risk assessment considered US EPA limits, limits specified in Australianstandard AS 2022 as well as Shelter in Place literature developed by FESA. Out of the availableliterature, the most conservative estimates were used by the risk assessment.

Ammonia risks will be dealt with in Major Hazard Facility licensing processes with the Department ofMinerals and Petroleum and is not part of the scope of the PER. A detailed Risk Assessment will becarried out for the site, and outcomes from that will be guiding the engineering decisions. Assessmentwill be in accordance with Australian Standards, which are comparable to US standards.

(76) SWIM Issue

Public risk does not consider Sulphur a risk in the project - proponent needs to fully explain why this is so


Sulphur will be removed from the syngas stream by the Sulphur recovery unit, to ensure minimal SOXemissions from the gas turbine exhaust stack. The Sulphur recovery process selected produces abiosulphur that is well suited to agricultural fertiliser use. Sulphur is not classified as a dangerous goodand does not pose a risk to the public.

(77) SWIM Issue

The proponent should detail any mitigation to risk that may be available from different technologies inammonia production and coal gasification


The PCF design will be use proven specifications and design best practices which have beenestablished from more than 50 years of history of ammonia production. The design will have several


inherent risk mitigation factors. PCF will follow a rigorous Safety in Design process, during engineeringstage, to allow rigorous Hazard Identification early during the design. All identified hazards will besubjected to risk assessment process and control measures will put in place to reduce the risk to As Lowas Reasonably Practicable (ALARP) level. As a Major Hazard Facility, PCF plant will develop a SafetyCase as part of Major Hazard Facility approvals by the Department of Minerals and Petroleum.


Worker safety and health due to inhalation risk of ammonia vapours


Comprehensive risk assessment of the plant is achieved through a Formal Safety Assessment processthat runs through the entire design phase. This process will be completed during the safety casedevelopment. Safety Case process allows extensive review of the risks associated with the plant andcontrol measures implemented and makes an assessment of the operator’s ability to achieve safeoperations.

(138) RAG Issue

Could PCF confirm that all ammonia emissions from the plant have been included in the modelling thatthese emissions represent worse case ammonia emissions and modelling is under worst case weatherconditions as they specifically relate to Collie?


Besides ammonia emission that may occur in an unlikely event of ammonia leak, fugitive emissions(generally below 2-3 ppm) of ammonia will be considered during National Pollutant Inventory (NPI)assessment. Compliance to design best practices ensures insignificant fugitive emissions in ammoniaplants.

(157) RAG Issue

RAG is of the view that this submission is not approved until a comprehensive risk assessment iscompleted.


Premier Coal's coal handling facility, administration building and workshop is located about 1.3 km fromthe closest boundary. Appropriate risk management and emergency response strategies must beestablished and communicated for all people at or near the Shotts Industrial Park.


Comprehensive risk assessment of the plant is achieved through a Formal Safety Assessment processthat runs through the entire design phase. This process will be completed during the safety casedevelopment. Safety Case process allows extensive review of the risks associated with the plant andcontrol measures implemented and makes an assessment of the operator’s ability for safe operation.


(158) RAG Issue

The PER states the "affected population" is assumed to be all residences and businesses within 5 km ofthe proposed site, estimated at 120 persons including Stockton lake recreational area (Section 6.13.3).This is a gross underestimation.

(163) RAG Issue

Despite Appendix K Section 4.6.2 Table 4.7. showing the distance from source of an ammonia plumereleased as Scenario MAE 3 being 2310ppm (10 times the level considered seriously damaging tohealth) at 8km away, and despite the very limited considerations used in the risk assessment, itconcludes "No risk" to Collie outskirts for MAE1 and MAE2 and only 15% risk of the incident affectingCollie outskirts for MAE3 Appendix K Section 2.9.3. Since the prevailing wind (about 35% of the time) isshown in the PER Appendix D Section 4.3.3 as SSE to ESE, ie the very direction of Collie townsite fromthe proposed site, this seems to be underestimated.


Offsite populations at risk from major ammonia releases were defined by reviewing site drawings andother published information and confirmed by subsequent research. That there is no risk to Collieoutskirts from MAE 1 and MAE 2 is based on the calculated effect distances. A 15% likelihood of theincident affecting the population is an estimate taking into account the wind direction, the width of theplume and the dispersion due to terrain, woodlands and buildings. Refer to responses below.

(159) RAG Issue

The PER risk assessment dispersion modelling results (Appendix K Section 4.6.2) show areas thatwould be affected by Scenario 1 and 2 as <2000m. Scenario 3 results show a maximum of 8000m.Based on reports of ammonia releases found on the internet and on basic dispersion models provided bythe US EPA, RAG believes these figures are vastly underestimated.


This comment does not site citing any specific references. The effect distance depends mainly on thesize of release, inventory released, and the conditions of release. A paper presented at AIChE SafetySymposium in 2008 ( a highly regarded forum for discussing safety issues related to ammonia industry)calculated 1,000 ppm at a distance of 2,780 m downwind resulting from a 25,000 tonnes release. Thecalculation approach is fully detailed and is underpinned by references for published data for ammoniatoxicity. Similarly, dispersion modelling has applied industry standard software tools and all results andcalculations have been checked and confirmed by sensitivity studies.

These and other risk issues will be addressed as part of a detailed risk assessment which will beundertaken as part of the Major Hazard Facility licensing processes with the Department of Minerals andPetroleum and is not part of the scope of the PER.


(160) RAG Issue

An accident, equipment failure or sabotage at Perdaman's plant resulting in the release of 10,000 tonnesof ammonia, more than 10,000 times as much as at Karratha - would obviously be catastrophic. For thePER to conclude only a 1-25% risk of populations within 5 km of the plant being affected during theaccidental release of up to 10,000 tones of anhydrous ammonia ( PER Appendix K, Section 2.9.3) isridiculous.

(161) RAG Issue

The PER risk assessment (Section 6 and Appendix K) appears to be extraordinarily underestimated as itonly considers the area likely to have very high fatalities in the event of an accidental ammonia release,i.e. concentrations down to 2310ppm ammonia.


There is no recorded incidence of a failure of an operational double-walled ammonia tank, of the naturePerdaman will construct at Collie, around the world.

In the event that a significant ammonia release did occur, the resulting gas plume from the plant will haveinitial dimensions defined by the size of the contained evaporating liquid pool. This will create a 'corridor'of gas dispersing downwind; as the plume disperses, it will eventually rise and, will be affected by terrain,flora and obstacles at all stages of its dispersion path. In an unlikely event that an intact ground levelcloud exists in the vicinity of Collie town it will remain as a relatively narrow gas plume which could onlyaffect a fraction of the entire populated area. It is not correct to imagine a downwind ammonia gas cloudas enveloping the entire town of Collie.

The risk to the Collie community from a significant ammonia release will be dealt with during MajorHazard Facility approvals for the project. An effective emergency response plan will be established andsignage will be placed at several places to provide directions to the general public in the unlikely scenarioof an ammonia leak. The assumption of 10,000 tonnes of ammonia in the tank is a very conservativeassumption. Tank levels in typical ammonia-urea plants are maintained around safe minimum levels forthe tank (approximately 500 tonnes) as the entire ammonia production is captively consumed by the ureaplant. PCF’s plant will have procedural controls in place to maintain low levels in ammonia tank.

(162) RAG Issue

In communications with PCF they state the probability of the ammonia tank catastrophically rupturing[3.42E6 (Appendix K, Section 2.6.2)] has now been halved to <1E-11, as since the PER was written theyhave decided to use a double-skinned tank (letter to RAG representative dated 2/10/09 from GaryWatson). PCF emphasises the low likelihood of a both skins of a double-wall tank spontaneouslyrupturing at the same time; we agree both inner and outer skins are unlikely to do so at same time. Butthey have not considered much more likely causes of an accidental ammonia release such as pipeworkand fitting failures (Appendix K Section 2.6.3). Neither have they considered much more likely causessuch as human error, refrigeration failure causing the ammonia to vaporise and pressurize the tank,overfilling the tank, truck/aeroplane crashing into tank, sabotage/terrorism, earthquake/subsidence,bush/industrial fire, explosion in another part of the process etc etc, the effects of most which would notbe highly mitigated by a second skin on the tank.



Refer previous comments on Major Hazard Facility approvals.

The preliminary risk assessment, included in PER, considers failure of piping or fittings as scenario MAE2. Any leak from pipework or fittings will only result in limited release of ammonia as all pipeline sectionswill be designed to be isolated by use of automatic and manual isolation valves. The design of therefrigeration section will consider two 100% duty compressors and flaring capacity equivalent to 100%boil off gas load to allow safe flaring of ammonia in case of failure of the refrigeration compressors. Thetank design will also consider seismicity and wind loads as per Australian Standards and relevant designcodes. The design of ammonia storage facility including refrigeration section will be subjected to rigorousrisk assessment process involving HAZID, HAZOP to identify risks. Control measures will beimplemented as required to reduce the risk to ALARP. Safety Instrumented Functions will be included inthe design to reduce reliance on automatic corrective actions (minimal human intervention). Proceduralcontrols (authorised access procedures, contraband procedures, traffic management plans, site security)will be implemented to reduce the risk from terrorism etc.


The community is very concerned about the risks of an ammonia accident. These concerns should beacknowledged and appropriate strategies to mitigate the risk should be developed and given to thecommunity.


Besides the inherent risk mitigation features included in design, PCF will follow a rigorous safety indesign process to identify risks from an ammonia incident and will implement control measures to reducethe risk to As Low and Reasonably Practicable (ALARP). PCF is also committed to an extensive andtransparent stakeholder engagement process during the design, construction, commissioning andoperation phase of the plant. The stakeholder engagement is also facilitated through process such asPER, safety case development etc.

(193) Department of Mines and Petroleum Issue

Risks Presented in this facility may not meet the EPA off-site individual risk criteria for fatalities fromhazardous plant

Proponents Response to Department of Mines and Petroleum Issue

The risk assessment presented in the PER was a preliminary level of assessment to identify key issuesassociated with the plant and proposed site. A detailed risk assessment will be undertaken as part of theMajor Hazard Facility licensing processes with the Department of Minerals and Petroleum and is not partof the scope of the PER. Perdaman has contacted DMP and it agrees with this.

6.7.1 Heritage

(107) Department of Indigenous Affairs (DIA) Issue

There are no Indigenous heritage issues or concerns for the Perdaman Collie Urea Project.


Proponents Response to DIA Issue

Noted. Perdaman have committed to additional heritage assessment for the associated infrastructurecorridors, including consultation with relevant Indigenous groups, once further design details areavailable.

6.7.2 Public consultation

(78) SWIM Issue

A more rigorous indigenous consultation be undertaken by PCF directly, to include areas not covered bythe Shotts industrial park report submitted as part of the PER


Perdaman has committed to additional heritage assessment for the associated infrastructure corridors,including consultation with relevant Indigenous groups, once further design details are available.

(111) Forest Products Commission Issue

FPC not consulted during the stakeholder consultative process

Proponents Response to FPC Issue

Perdaman has arranged a meeting with PCF to discuss the project.

6.7.3 Transport


Concerns regarding the capacity of the highway to sustain heavy use transporting infrastructure and thedaily workforce. How much of the tax payer dollar will be spent to upgrade the road.


Perdaman have been advised by Main Roads that the existing road network is sufficient and capable tohandle the predicted traffic loads without any substantial upgrades. Main Roads is currently proposing anupgrade between Allanson and Collie, independent of the Perdaman proposal.

(155) RAG Issue

RAG requests that PCF considers restricting train movements to day time hours. Outside school timesschool children are on roads and preferably outside of main shift change times at other large industrialsites. RAG is concerned that no analysis of train movements during the operational phase of the plantwas undertaken.


There is little detail as to how rail movement during peak traffic periods will impact local traffic. A trafficmanagement plan is requested to be developed with Premier Coal to consider the interaction betweenrail movements and peak traffic periods.



The timing of rail movements is outside Perdaman's control. Perdaman is required to operate trains inaccordance with specific train path times stipulated by Westnet, to ensure that train operations arescheduled to avoid train congestion. The Brunswick Junction to Bunbury rail line is heavily utilised andPerdaman will be taking the last remaining train paths on this section of railway line.

Perdaman has already committed to the Collie Industry Road Safety Alliance and will work with allindustries and the Shire in minimising transport related impacts from the project. Perdaman cannot setrail movement times as these are controlled by Westnet Rail, but it will work with other Collie industrialcompanies to coordinate shift change times to avoid train movement times. Perdaman has alsodiscussed the installation of upgraded signalling between Collie and Shotts Industrial Estate and Westnetis now planning to do this.


Premier Coal requests that PCF considers the installation of slip lanes on the Collie -Lake King road toreduce the impact of other traffic using the road.


Perdaman will pass this request on to LandCorp, who is responsible for road access to Shotts IndustrialEstate.

(187) FOESWA Issue

The risk of a train accident on a steep grade and the risk of urea being washed into the Collie River andthen the Leschenault Estuary and ocean is a major concern.


Urea will be transported in purpose designed wagons that will incorporate metal covers. The covers willbe designed to contain the urea in the railcar and prevent weather ingress. Attention will be paid toprotection against loss of containment in the event of accident and derailments.

(188) FOESWA Issue

The use of fossil fuels to transport the fertiliser across the world and the impact of shipping polluting boththe oceans and atmosphere should not be supported.


This is not within the scope of the Collie Urea project PER. Perdaman would comment though that theurea would be manufactured and shipped from another destination to meet demand if it weren't shippedfrom Bunbury.


6.8 Management Plans

(104) DEC Issue

The plant proposal is located within a zone categorised as an extreme bushfire risk. That the proponentdesigns and builds the plant to include appropriate fire protection within its lease area and does notentirely rely on fuel reduction and fire suppression activities within the state forest. That the firemanagement plan adheres to the points listed in the DEC submission


Perdaman will comply with all regulations and requirements from DEC. A Fire Management Plan will bedeveloped in consultation with DEC.

(105) DEC Issue

The DEC, local bush fire brigades and the Collie Town Fire and Rescue Service does not currently havethe capacity to suppress plant or chemical fires at the proposed plant. It is recommended that a riskassessment is undertaken to develop a plan to manage possible future structural and chemical fires withthe urea plant as proposed.


Perdaman will comply with all regulations and requirements from DEC. A Fire Management Plan will bedeveloped in consultation with DEC. Perdaman will be installing a ring main fire protection system withmonitors that will be capable of dousing any fire within range and protecting the plant in the event ofbushfire. Bushfire Risk will be a key element in any risk management studies undertaken as the projectproceeds.

(20) SWIM Issue

Generic commitments to management plans should be avoided, a more rigorous approach would be toformalise specific management plans in the PER at least to Table of Contents (TOC) stage and includekey commitments which are measureable and enforceable. These commitments would then be includedas part of the approval process by EPA


Detailed construction and operational phase Environmental Management Plans will be developed as partof the Part V environmental approvals. Perdaman has committed to work with the Department ofEnvironment and Conservation in developing these plans (Refer to comments in the followingresponses). Prior to more detailed design information, it is not possible to develop more specific ormeaningful commitments.

(103) DEC Issue

The connection between monitoring/auditing and environmental performance and compliance for thisproject to be clarified. That the following recommendations are adhered: i) That the strategies listed in


7.1.1 be cross-referenced with success criteria to allow auditing and be included in individual plans; ii)that the individual plans ensure that monitoring is an audit or quality control process and is an integralpart of project management of all construction work. and iii) that the individual plans also provide for:dieback management - control action to prevent the spread of dieback in addition to the monitoring ofpresence or spread; Topsoil stockpile management - weed control and signposting; Seed CollectionManagement - storage, records and reuse; Fire Prevention Management - in accordance with a firemanagement plan for construction and operation; Burning off of vegetation debris, if intended - permits,equipment, control and responsibility; Management of cleared vegetation - timber, plants.


In developing management plans, including requirements for monitoring and auditing, compliance will bechecked against the strategies listed in Section 7.1.1 of the REF and success criteria developed to allowauditing. The plans will incorporate monitoring as an audit or quality control process as a key part ofproject management for all construction works. Individual plans also need to address diebackmanagement, topsoil stockpile management, seed collection management, traffic management, fireprevention management, burning off and management of cleared vegetation as outlined in the DECsubmission.

(106) DEC Issue

The water supply pipeline construction management measures are insufficient to effectively manageenvironmental risk. The DEC recommends that the proponent provides a pipeline environmentalmanagement plan for the construction and operation phases and that this plan provides for,Environmental protection, Fire appliance cross-overs, sustainable firebreaks, vehicle turnaround pointsand erosion control. The maintenance of pipelines including public access, pipe crossing points,waterway crossing points, sustainable firebreaks, biosecurity, erosion and fire hydrant access.Vegetation clearing controls for waterway crossings. Daily fauna entrapment clearance from trenches,Disturbance footprint details for the new or upgraded pump station at Wellington dam and erosion andclearing controls. It is recommended that the proponent sees the advice of DEC via the WellingtonDistrict office in the development of the pipeline environmental management plan for the constructionand operation phases referred to in Recommendation 12.


Perdaman will work with DEC in developing appropriate pipeline construction measures to address thoseissues raised in the submission including but not limited to environmental protection, fire appliance cross-overs, sustainable firebreaks, vehicle turnaround points and erosion control. The maintenance ofpipelines including public access, pipe crossing points, waterway crossing points, sustainable firebreaks,biosecurity, erosion and fire hydrant access will be considered. Vegetation clearing controls for waterwaycrossings will be detailed. Daily fauna entrapment clearance from trenches, Disturbance footprint detailsfor the new or upgraded pump station at Wellington dam and erosion and clearing controls will beaddressed in the plans. Perdaman will seek advice from the DEC via their Wellington District office asproposed.


6.9 Other


The PER has not established whether the proposed urea production plant would require a buffer zonethat could potentially restrict mining or other industrial activities bordering the Shotts Industrial Park.


A buffer zone is currently being considered as part of the Shotts Industrial Park development. The buffer,as currently proposed, would not exclude mining or other industrial activities.


Arrangements will be required and formalised to ensure that works occur safely and are totallyindependent of Premier Coal's jurisdiction (where work is to directly occur on Premier Coal land)


Perdaman will work with LandCorp and neighbouring landholders to address current and future adjacentland uses.

(14) SWIM Issue

Proponent should prepare a detailed location analysis to allow the EPA to competently assess the bestlocation for the plant site which should include why the established Kemerton Industrial Estate has notbeen considered suitable for this project.


The justification for proposing the site has been identified and discussed in the PER in Section 3. TheKemerton Industrial Estate does not provide access to rail infrastructure, a key logistical requirement ofthe project. The additional distance from the coal supply source associated with an operation atKemerton would add to the environmental footprint of the project.

(101) DEC Issue

The PER does not adequately describe the source and availability of the process feed limestone and thepotential impacts on biodiversity as a result of extraction. The proponent is to i) provide information onthe source and availability of the process feed limestone with a view to assessing the impacts onbiodiversity as a result of this extraction; and ii) clarify that the limestone is not going to be sourced fromenvironmentally sensitive locations including the Leeuwin-Naturaliste Ridge or from state forest, whereadditional clearing of native vegetation would be required.


The lime required for the process is not of a high grade. The required limestone will be sourced from thelocal suppliers of Agricultural lime. This issue was discussed with EPA and it was agreed that PCF neednot address the environmental impact of limestone extraction, as the suppliers of the limestone aresubject to separate environmental regulation.


(13) SWIM Issue

PCF should include a binding commitment to biomass feedstock with targets and timetables established.The gasification technology provider should be required to provide commitment that gasificationequipment can process biomass feed without additional burden to existing airshed


Perdaman is currently evaluating biomass as an option to reduce CO2 emissions. Subject to a suitableand commercially mature options, Perdaman will consider these as part of detailed design or as a futuremodification to the project. At this stage it is not possible to commit to specific targets.

(5) SWIM Issue

Proponent should provide a position statement on decommissioning and an environmental bond shouldbe established to ensure future compliance


An environmental bond is not a requirement of the PER but will be considered as part of Part Vapprovals.

(6) SWIM Issue

Decommissioning costs could be estimated as a factor of CAPEX discounted over project life. At the $3.5billion capital cost this could be `$175 million, based on 5% of total fixed investment (Source industryaverages publicly available)


Decommissioning cost are not a requirement of the PER but will be considered by Perdaman as part ofproject feasibility.

(11) SWIM Issue

An overall economic analysis should be provided by the proponent as to why coal is the best option forWestern Australia at this time given other Urea projects planned for Western Australia and Australia aregas based.


This question is not related to project environmental approvals. Natural gas is not available to Perdamanat a competitive price over a sufficient period for downstream processing into Urea. The current andpredicted price of gas as a result of increasing demand for gas in power generation is not expected tomake the production of urea from gas economically viable in future.


(1) SWIM Issue

Mass balance needs to be developed as part of the PER


A mass balance model will be prepared as part of ongoing design and will be part of informationconsidered in finalising Part V approvals. This is not a requirement of the PER.

(58) SWIM Issue

What form will the sulphur be in after recovery from its gasification process - will it be in a dust orgranulated form or will it be a prilled product


Sulphur is recovered in a biological process. The Bio-Sulphur will be in the form of wet hydrophilliccakes.

(59) SWIM Issue

How is the sulphur to be stored on site - enclosed shed or open storage yard, bagged or bulk


Bulk storage in a shed.

(61) SWIM Issue

Transport of the sulphur product - will it be containerised, open truck or rail, enclosed or open rail cars. Aserious issue which may result in public umbrage similar to the experience in North America


Will be transported in closed trucks for Agricultural use.

(7) SWIM Issue

Why has the Shell gasification process been chosen when it has proven unstable?


PCF has provided independent expert reports as part of the PER (Appendix M) reviewing thetechnologies proposed. Any reported issues with 'stability' of Shell gasification technology have beenproven attributable to indirect factors, principally inconsistency of coal quality and design/reliability ofutilities, particularly the Air Separation Unit. Coal quality variability occurs in China because coal issourced from a range of different mines and transported to the urea plant. The gasification process isvery sensitive to the variability of coal feed and so it is important to ensure wherever possible a singlesource for the coal, as will be the case for the Collie plant. Griffin's coal supply to PCF will be blended inthe stockpile to eliminate any minor variability in quality that arises within the mine. Shell technology initself was not at fault in the referenced plants.


(8) SWIM Issue

Proponent needs to submit a technology review which allows the EPA to assess that the chosentechnology is best in class environmentally


This has been done. PCF has provided independent expert technical reports as part of the PER(Appendix M) reviewing the technologies proposed.

(9) SWIM Issue

Proponent should amend PER to clarify ambiguity in process/definition and revised PER should be madeavailable for public review/comment


One of the specific clarifications sought is the basis of Coal. 'As Received basis' means the coal asreceived from the Griffin Mine. No other specific questions have been asked but PCF is happy to addressany such questions.


b) The PER states that "urea enhances plant growth which in turn biosequesters carbon". This is onlytemporary, as Perdaman intends to use the urea mainly to grow rice in India for human consumptionthen subsequently use the dry rice husks as biomass. Both processes will eventually release the carbonwhich was once stored in the coal.


The use of rice husks if used as biomass, will offset the equivalent use of fossil fuels which otherwise willhave to be extracted to fullfil the need for energy. Also, globally it is demonstrated that the amount ofcarbon stored in the roots and soil will be more than that stored in the folliage.

(186) FoESWA Issue

The continued use of urea is unacceptable as there are high risks associated with this product.


Perdaman disagrees with this statement. Urea is a safe product when applied correctly.


Doubts over the potential to employ local workforce. How many of the proposed 1200-1500 constructionphase and 200 operation phase employees will be from the local market? It is my understanding thatplant equipment will mostly be contracted off-shore by a Korean company, Samsung, shipped to Bunburyand transported by road to the Plant site to be assembled. For what purpose and to what extent?



Perdaman has stated publicly that it expects to spend as much as A$2 Billion in the local market. Someitems of equipment are of a specialised nature and will have to be manufactured offshore and shipped toCollie as there is no manufacturing available in Australia. In relation to employment, Perdaman haspublicly committed to giving local people ‘first go’ at any available jobs during construction andoperations.


7. References

Environmental Impact Assessment (Part IV Division I) Administrative Procedures 2002 (EPA, 2002)

Le Provost I., Semeniuk V. and Chalmers L., 1983. Bunbury C Power Station, Marine EnvironmentalStudies. Report prepared for the State Energy Commission.

Maunsell, 2008, Literature Review – Fish Larval Studies, Prepared for Water Corporation, Document No.60039425.

Stamicarbon Urea Process Data Sheet V3-05-2009

Uhde 2009. Urea Printed 22 January 2009

Walker M. H., 1979. Inventory of Marine Resources of the Bunbury Marine Area and Geographe Bay.Department of Fisheries Report.


Appendix A

Submission Issues


Table 4 Submission Issues Addressed in this Supplementary Report

Item Submission Issue

1 South West Integrated Management Mass balance needs to be developed as part of the PER

5 South West Integrated Management Proponent should provide a position statement on decommissioningand an environmental bond should be established to ensure futurecompliance

6 South West Integrated Management Decommissioning costs could be estimated as a factor of CAPEXdiscounted over project life. At the $3.5 billion capital cost this couldbe `$175 million, based on 5% of total fixed investment (Sourceindustry averages publicly available)

7 South West Integrated Management Why has the Shell gasification process been chosen when it hasproven unstable?

8 South West Integrated Management Proponent needs to submit a technology review which allows theEPA to assess that the chosen technology is best in classenvironmentally

9 South West Integrated Management Proponent should amend PER to clarify ambiguity inprocess/definition and revised PER should be made available forpublic review/comment

10 South West Integrated Management Proponent should provide information on emission and wastevolumes whilst plant is in unstable operation

11 South West Integrated Management An overall economic analysis should be provided by the proponentas to why coal is the best option for Western Australia at this timegiven other Urea projects planned for Western Australia andAustralia are gas based.

12 South West Integrated Management The PER has not specifically addressed how waste material will bemanaged or disposed of nor does the PER address ancillary issuesassociated with land clearing for storage of wastes or transportationissues.

13 South West Integrated Management PCF should include a binding commitment to biomass feedstock withtargets and timetables established. The gasification technologyprovider should be required to provide commitment that gasificationequipment can process biomass feed without additional burden toexisting airshed

14 South West Integrated Management Proponent should prepare a detailed location analysis to allow theEPA to competently assess the best location for the plant site whichshould include why the established Kemerton Industrial Estate hasnot been considered suitable for this project

16 South West Integrated Management Alternative carbon capture/offsets schemes should also be subject tofull rigour of a PER

17 South West Integrated Management The proponent should detail how the caustic effluent will betransported to the Shotts site, or if another pipeline will be requiredto take the CO2 to the alumina producers. Further the proponentshould detail the process of mineralisation, the quantity of effluentand the ratio of CO2 to effluent, and finally the disposal mechanismfor the final product including transport implications

18 South West Integrated Management Land clearing off sets have not been addressed in the PER both forthe development of the Shotts site, extra clearing along the proposepipeline routes and for the land clearance required for the expansionfor the Muja coal mine site in relation to coal extraction for the PCFproject.



19 South West Integrated Management SWIM would propose that the proponent should commit to bindingtargets for carbon offsets in the PER and contract to purchasingcarbon offsets through 3rd party entities to ensure transparency.Additionally the proponent should be directed to provide anenvironmental bond on carbon offsets to ensure the State hassufficient coverage on CO2 should technology prove to be unreliablefor sequestration.

20 South West Integrated Management Generic commitments to management plans should be avoided, amore rigorous approach would be to formalise specific managementplans in the PER at least to Table of Contents (TOC) stage andinclude key commitments which are measureable and enforceable.These commitments would then be included as part of the approvalprocess by EPA

21 South West Integrated Management It is not unambiguously clear whether or not the environmental factorof vegetation forms part of this assessment or if it will be assessedunder the proposed amendment to the Collie Town PlanningScheme (Shotts Industrial Park)

22 South West Integrated Management There are significant inconsistencies between the stated scope andscale of disturbance to native vegetation between the variousdocuments describing the proposal, including the ESD and the PER,and within the PER itself

23 South West Integrated Management The level of detail pertaining to the clearing of and potential impactsto native vegetation for the infrastructure corridors is not sufficientlydefined to conduct a proper assessment and for compliance auditingpurposes

24 South West Integrated Management There is no specific plan to dispose of coal wastes (slag) generatedas a by-product from the process

25 South West Integrated Management The potential impact on biodiversity at the species and ecosystemlevels has not been sufficiently described. The EPA advises that thenatural significance of species and communities is not limited to theirlist status, but also applies to their local contexts and role inmaintaining natural values and functions (eg EPA 2004, 2008a).Such aspects have not been presented in the PER. Without thisinformation it cannot be seen how a transparent assessment can bemade by the EPA or the Minister for the Environment

26 South West Integrated Management There is no justification provided for the clearing requirement, i.e.there is no discussion of why the proposal cannot be constructed onpreviously cleared land, nor is any rationale provided for the size ofthe clearing footprint or those steps taken to avoid disturbingvegetation. This shortfall applies to both the sites and theinfrastructure corridors.

27 South West Integrated Management The PER makes no attempt to present information that woulddemonstrate to the EPA that the proposal would not cause anyassociation or community of indigenous plants and/or animals tocease to exist. This is particularly relevant in the Collie Basin, whichis a unique and restricted landform and under pressure from anumber of sources and processes including mining, salinity andgroundwater (DoW 2009)

28 South West Integrated Management The PER presents no information to show whether or not theproposal would not compromise any vegetation type by taking itbelow the 'threshold level' of 30% of the pre-clearing extent of thevegetation type. Information in this regard in the relevant appendix(Appendix G) utilises the extremely coarse Beard VegetationAssociation, which is considered by the EPA (2006) and others (egESCAVI, 2003) as being too coarse for assessing impacts oncommunity representativeness.



29 South West Integrated Management No verifiable information is provided by the proponent to verify itsstatement in the PER that vegetation on the site is "relatively similarto local native vegetation occurring in the surrounding region andwell represented locally and regionally" (p iv of Exec. Sum.).

30 South West Integrated Management No information has been provided by the proponent to demonstratethat there is comprehensive, adequate and secure representation ofscarce or endangered habitats within the project area and/or inareas which are biologically comparable to the project area,protected in secure reserves.

31 South West Integrated Management Not all on-site and off-site impacts of the proposal have beenidentified as per EPA requirements, particularly those relating toclearing for corridors and secondary impacts from gaseous andother emissions, and that it has not been demonstrated that theseimpacts can be managed.

32 South West Integrated Management The proponent has not presented any information on the potentialimpacts of the proposal on the existing biodiversity conservationrecommendations of the national frameworks to which WesternAustralia is signatory to. These include the Regional ForestAgreement and the WA Forest Management Plan, the NationalBiodiversity Strategy and its Principles for Biodiversity Conservation

33 South West Integrated Management The proponent has not presented any information describing howthe proposal might affect the outcomes and recommendations of thenational 2002 Biodiversity Audit (CALM, 2003), which was based onthe IBRA units, the southern and central Jarrah Forrest units thatsurround the site

34 South West Integrated Management The proponent has not satisfied the requirements of the EPA inregards to the information and scope of field surveys of nativevegetation and does not present sufficient information to addressboth biodiversity conservation and ecological function values of thesite and its surrounds

35 South West Integrated Management The PER does not accurately and sufficiently present the findings ofthe vegetation surveys commissioned by LandCorp and does notinclude all of the survey reports or data for analysis

36 South West Integrated Management In assessing the information presented in the PER against EPAGuidance Statement No. 10, the following observations can bemade: The Proposal lies within the Collie Basin, which is a uniqueand regionally restricted landform. No assessment of the adequacyof the Reserve System has yet been undertaken for the Collie Basinand areas of Crown Land should not be cleared for industrialpurposes until it has been demonstrated that such clearing will notimpact on Regionally Significant Areas, as per Guidance No. 10.

37 South West Integrated Management The survey effort for the wastewater pipeline, as reported inAppendix G, needs to be clarified to ensure that the effort is suitablefor the complexity of the survey area and that the timing of thesurvey was appropriate.

38 South West Integrated Management The proponent should provide its response to EPA feedback to itsoriginal 2007 flora survey of the proposal site, as well as making thesurvey available to the public.

39 South West Integrated Management The vegetation survey presented as a appendix to the PER does notidentify or discuss the limitations of the survey, so falls short of theEPA expectations in regards to rigour of reporting

40 South West Integrated Management The surveys conducted do not extend outside of any potential impactareas, so the assessment of local and regional impacts, ascommitted to in the ESD and as required by EPA, cannot be reliablyundertaken



41 South West Integrated Management The proponent has not collected any floristic data from standardquadrants, as per the Guidance Statement, so comparison againstpreviously described Priority Ecological Communities cannot bemade

42 South West Integrated Management The proponent has not addressed the native vegetation clearingprinciples of Schedule 5 of the Environmental Protection Act 1986 inthe PER

43 South West Integrated Management In addressing the information presented in the PER against DECdraft Policy Statement No. 9, the following observations can bemade: The absence of previously described Threatened EcologicalCommunities (TEC) within or surrounding the proposal site does notautomatically confer the absence of such communities, as it isunlikely that the area has been previously surveyed to such a level.

44 South West Integrated Management The PER contains no information on the local significance of thevegetation and flora of the proposal site or other importantecosystem functions.

45 South West Integrated Management The proposal does not satisfy EPA Bulletin No.1 in that nobiodiversity offsets are actually proposed, only suggested. Theproponent needs to assess the residual impacts to biodiversity asper EPA guidance and identify suitable offsets for those impacts thatcannot be otherwise avoided or managed

46 South West Integrated Management Proponent needs to specify how it intends to ameliorate any impacton breeding sites, commit to habitat preservation and highlight anyrevegetation options available at the Shotts site or any other sitedisturbed by PCF's operations to both the Carnaby's and Baudin'sblack cockatoo's

47 South West Integrated Management Proponent should conduct a more thorough fauna survey not just atthe Shotts site but along the proposed pipeline corridors

48 South West Integrated Management The Proponent needs to address any risk posed to downstreamusers of water streams including dairy that may be urea enriched

49 South West Integrated Management Proponent needs to detail how it will prevent a deleterious impact onsurrounding areas from declared plant species currently identifiedwithin the proposed Shotts due in part to further disturbance of landand also the increased nutrient load that will arise from the plantemissions

50 South West Integrated Management Storm water management plans should be established and detailedprior to the PER being finalised, as urea and sulphur enriched run offcould have a significant impact on the wetlands

51 South West Integrated Management Proponent needs to further detail how it will ameliorate CO2emissions to ensure that State and National CO2 targets can be met.Alternatively the proponent should be made to commit to biosequestration as part of its approval

52 South West Integrated Management The proponent should provide a summary of the various gasificationtechnologies available with a view to the modelled carbon emissionsfrom each technology

53 South West Integrated Management Public Health Impact needs to fully explore the issue of atmosphericimpacts from the plant and operations - there are manyconsiderations to cover in this. A full health Impact statement shouldbe prepared by the proponent and all questions raised in theatmospheric contaminants of this report should be addressed

54 South West Integrated Management Proponent needs to predict what increased Urea concentrations willbe in the Port region, Koombana Bay and Leschenault inlet waterways. Proponent needs to indicate how it will mitigate marineincursions and manage longer term impacts



55 South West Integrated Management Water borne urea will flow through prime dairy country in the LowerCollie River Valley - what public health risk arises from this givenrecent events in China

56 South West Integrated Management Additional overburden, coal waste and slag will also arise from thequestions surrounding the mass balance. The proponent needs toaddress all these issues fully in the PER as mine clearance

57 South West Integrated Management The critical solid waste management of Mercury is not specificallyaddressed in the PER

58 South West Integrated Management What form will the sulphur be in after recovery from its gasificationprocess - will it be in a dust or granulated form or will it be a prilledproduct

59 South West Integrated Management How is the sulphur to be stored on site - enclosed shed or openstorage yard, bagged or bulk

61 South West Integrated Management Transport of the sulphur product - will it be containerised, open truckor rail, enclosed or open rail cars. A serious issue which may resultin public umbrage similar to the experience in North America

62 South West Integrated Management The proponent should specify how it plans to store any slag from theoperation with particular emphasis on dust suppression. Also noimpact on transport for this material has been included in the PER. Ifthe slag is to be stored or retained longer term on site then the PERshould cover the rehabilitation plan for any slag piles that may be left

63 South West Integrated Management The LWMS should be made available for public review prior to beingsubmitted for approval by government agencies

64 South West Integrated Management The proponent should include in the LWMS a salt-volume balancefor the saline discharge, that is, the maximisation of water re-useand recycling before ocean pipeline discharge criteria for salt arereached

65 South West Integrated Management The proponent needs to more clearly state how they will manage thesaline outfall in the event of a significant down time period of theVerve pipeline. Namely:

65a South West Integrated Management How large will initial settling ponds be

65b South West Integrated Management What time frame before brine concentrator is operable after a shutdown period

65c South West Integrated Management What size will the settling ponds for the concentrated brine be, willthey be lined/covered

65d South West Integrated Management What method will be employed to combine fly ash and concentratedbrine

65e South West Integrated Management What method will be employed to further stabilise brine/fly ash

66 South West Integrated Management Proponent also needs to detail what quantity of fly ash will berequired to trap concentrated brine, quantity of truck movements forboth inbound fly ash and outbund stabilised solid waste

67 South West Integrated Management Proponent has not provided modelling of the marine impact of theincreased saline outfall on new developments on the coast atBinningup

68 South West Integrated Management The proponent should revisit the PER in light of the Upper CollieWater Allocation Plan (DoW - Aug 2009) and again review theproposed location as an alternate location may provide more secureaccess to the….(Incomplete in the submission)

69 South West Integrated Management Proponent should detail where the off take from Wellington dam willbe situated and how this will impact on overall salt levels in


Item Submission Issueconjunction with the DoW sourcing process

70 South West Integrated Management Environmental modelling of noise emissions should be expanded toinclude alternate modelling in line with best practice forunderstanding industrial noise emission

71 South West Integrated Management Noise modelling should also include impact on transport routes

72 South West Integrated Management It is prudent that an operation of this scope in relative proximity to asignificant community (Collie and surrounds) warrants thedevelopment of a full Health Impact Statement

73 South West Integrated Management Could the proponent increase the number of ammonia storagevessels and thus reduce the magnitude of any emergency eventsand therefore public risk

74 South West Integrated Management Why has the risk assessment failed to consider sub-lethal, i.e.chronic risks that might arise from a 'cocktail' of potentially toxicemissions in an already overloaded airshed

75 South West Integrated Management The assessment of Ammonia risk should be based on World's bestpractice limits as indicated by the US EPA limits

76 South West Integrated Management Public risk does not consider Sulphur a risk in the project -proponent needs to fully explain why this is so

77 South West Integrated Management The proponent should detail any mitigation to risk that may beavailable from different technologies in ammonia production and coalgasification

78 South West Integrated Management A more rigorous indigenous consultation be undertaken by PCFdirectly, to include areas not covered by the Shotts industrial parkreport submitted as part of the PER

80 Anonymous Letter 23rd November 2009 (ref. 7) b) The PER states that "urea enhances plant growth which in turnbiosequesters carbon". This is only temporary, as Perdaman intendsto use the urea mainly to grow rice in India for human consumptionthen subsequently use the dry rice husks as biomass. Bothprocesses will eventually release the carbon which was once storedin the coal.

85 Anonymous Letter 23rd November 2009 (ref. 7) Impact of mining and abstraction on groundwater

86 Anonymous Letter 23rd November 2009 (ref. 7) Additional clearing of land by Griffin for coal mining for PCFFeedstock.

87 Anonymous Letter 23rd November 2009 (ref. 7) Clearing will impact cockatoos breeding and other endangered fauna

88 Anonymous Letter 23rd November 2009 (ref. 7) Value of state forests for their soil conservation should not beoverlooked.

89 Anonymous Letter 23rd November 2009 (ref. 7) Value of state forests for their protection of surface and groundwaterquality should not be overlooked.

90 Anonymous Letter 23rd November 2009 (ref. 7) Value of state forests should not be overlooked for their capacity toCapture Carbon and produce a net oxygen gain.

91 Anonymous Letter 23rd November 2009 (ref. 7) Clearing will add to weed infestation, disease infestation, disruptwildlife corridors, affect groundwater and contribute to the drying outof surrounding forest areas.

92 Anonymous Letter 23rd November 2009 (ref. 7) Impact of clearing on the land and its surrounds. ManagementStrategy (Table 25, p 132) will not protect the fauna and we will loseflora biodiversity.



93 Anonymous Letter 23rd November 2009 (ref. 7) Runoff may become contaminated by hydrocarbons and maycontaminate receiving bodies. Clearing will result in sediment runoff.

94 Anonymous Letter 23rd November 2009 (ref. 7) Worker safety and health due to inhalation risk of ammonia vapours

95 Anonymous Letter 23rd November 2009 (ref. 7) Contaminants that may impact air quality including coal dust andother particulates.

96 Anonymous Letter 23rd November 2009 (ref. 7) The risk of particulates for example S or Urea being dispersed intothe forested area potentially destroying native vegetation.

97 Anonymous Letter 23rd November 2009 (ref. 7) Doubts over the potential to employ local workforce. How many ofthe proposed 1200-1500 construction phase and 200 operationphase employees will be from the local market? It is myunderstanding that plant equipment will mostly be contracted off-shore by a Korean company, Samsung, shipped to Bunbury andtransported by road to the Plant site to be assembled. For whatpurpose and to what extent?

98 Anonymous Letter 23rd November 2009 (ref. 7) Concerns regarding the capacity of the highway to sustain heavyuse transporting infrastructure and the daily workforce. How much ofthe tax payer dollar will be spent to upgrade the road.

99 Anonymous Letter 23rd November 2009 (ref. 7) The amount of water stated in the letter of advice to PCF does notstate 12 GL, rather that amount of water is provided from a range ofsources. The uncertainty of supply sources and the contingencyoptions if there is a series of dry years is concerning, especially ifpotable water is to be purchased, which will also be scarce in a dryyear.

100 Anonymous Letter 23rd November 2009 (ref. 7) The Verve waste water pipeline is not adequate and already hasleakage problems. Option 2 of the mine voids is not adequate andnot appropriate rehabilitation, what about the impact of salts thatmay leach into the groundwater.

101 DEC The PER does not adequately describe the source and availability ofthe process feed limestone and the potential impacts on biodiversityas a result of extraction. The proponent is to i) provide informationon the source and availability of the process feed limestone with aview to assessing the impacts on biodiversity as a result of thisextraction; and ii) clarify that the limestone is not going to besourced from environmentally sensitive locations including theLeeuwin-Naturaliste Ridge or from state forest, where additionalclearing of native vegetation would be required.

102 DEC The management proposed is inadequate from the clearing of nativevegetation. i) That the proposed clearing plan and floramanagement plan provide for the maximum recovery of timber,seed, whole plants and woody debris for use in revegetation and infauna habitat recreation; and ii) that any planned disposal ofvegetation by burning be minimised. Where burning is required, amanagement procedure should be submitted to the Chief Bush FireControl Officer for the Shire of Collie and to DEC for approval.



103 DEC The connection between monitoring/auditing and environmentalperformance and compliance for this project to be clarified. That thefollowing recommendations are adhered: i) That the strategies listedin 7.1.1 be cross-referenced with success criteria to allow auditingand be included in individual plans; ii) that the individual plansensure that monitoring is an audit or quality control process and isan integral part of project management of all construction work. andiii) that the individual plans also provide for: dieback management -control action to prevent the spread of dieback in addition to themonitoring of presence or spread; Topsoil stockpile management -weed control and signposting; Seed Collection Management -storage, records and reuse; Fire Prevention Management - inaccordance with a fire management plan for construction andoperation; Burning off of vegetation debris, if intended - permits,equipment, control and responsibility; Management of clearedvegetation - timber, plants.

104 DEC The plant proposal is located within a zone categorised as anextreme bushfire risk. That the proponent designs and builds theplant to include appropriate fire protection within its lease area anddoes not entirely rely on fuel reduction and fire suppression activitieswithin the state forest. That the fire management plan adheres tothe points listed in the DEC submission

105 DEC The DEC, local bush fire brigades and the Collie Town Fire andRescue Service does not currently have the capacity to suppressplant or chemical fires at the proposed plant. It is recommended thata risk assessment is undertaken to develop a plan to managepossible future structural and chemical fires with the urea plant asproposed.

106 DEC The water supply pipeline construction management measures areinsufficient to effectively manage environmental risk. The DECrecommends that the proponent provides a pipeline environmentalmanagement plan for the construction and operation phases andthat this plan provides for, Environmental protection, Fire appliancecross-overs, sustainable firebreaks, vehicle turnaround points anderosion control. The maintenance of pipelines including publicaccess, pipe crossing points, waterway crossing points, sustainablefirebreaks, biosecurity, erosion and fire hydrant access. Vegetationclearing controls for waterway crossings. Daily fauna entrapmentclearance from trenches, Disturbance footprint details for the new orupgraded pump station at Wellington dam and erosion and clearingcontrols. It is recommended that the proponent sees the advice ofDEC via the Wellington District office in the development of thepipeline environmental management plan for the construction andoperation phases referred to in Recommendation 12.

107 DIA There are no Indigenous heritage issues or concerns for thePerdaman Collie Urea Project.

108 Shire of Collie Noise criteria is to tie in with the proposed Local Planning SchemeNo 5 Amendment No.1. The noise monitoring and management planbe required to verify noise predictions and develop a method ofhandling complaints and reporting thereof.

109 Shire of Collie That an Urban Water Management Plan is identified as arequirement in the proposed Local Planning Scheme No 5Amendment No.1 and that some existing commitments can be dealtwith through that plan

110 Shire of Collie That commitments covering the clearing plan, noise monitoring andmanagement plan, and plans relating to stormwater management,weed management and waste management include the Shire ofCollie as an advising agency.

111 Forrest Products Commission FPC not consulted during the stakeholder consultative process



112 Forrest Products Commission The PER incorrectly notes P. pinasta - The PER notes it to be P.radiata 4.5.3 pg 61

113 Forrest Products Commission No objections raised.

114 Forrest Products Commission Sequestration rates for plantation forests are ambitious

115 Forrest Products Commission Currently no plans for additional 80,000 ha plantation foresttherefore proponent may need to review biomass projections (4.5.3)

116 Noise Branch - DEC Non-compliance at the Stockton Lake caretaker's cottage. The PERshould consider options for relocation or other solutions to this noisenon-compliance issue; and ii) that this issue be addressed andresolved with the appropriate authorities before the project isapproved

117 Noise Branch - DEC Predicted high noise level at Stockton Lake. The noise branchwould reiterate their recommendation that the proponent work withthe Shire and local community to develop an appropriate aspirationalgoal for noise emissions for Lake Stockton.

118 Noise Branch - DEC The Noise branch requests that the proponent demonstrate howpracticable the overall noise power level of the proposed urea plantcan be reduced to 11dB(A) , or at least 120dB(A).

119 Noise Branch - DEC 7dB noise reduction requirement for Bunbury Port Operations.Because the 7dB noise reduction is normally considered a goal thatis difficult to achieve for such as large port operation, the noisebranch would recommend that the proponent adopt all the noisecontrol measures proposed by LGA for the conveyor. Theproponent must do more than 'investigate installing balanced andmachined idlers on the conveyor'

120 Rural Action Group Identification of Sensitive receptors being determined from aerialphotographs is not adequate. Consistency of sensitive receiversrequired for Air quality and Noise reports. Section 8.1.2 Figure 27and Appendix Maps is required. Review noise impact results andclarify as they are based on the wrong receptors. Night time valuesare for the wrong receptors.

121 Rural Action Group Increases in noise at Cardiff and Collie Burn at 27 dB and 35dB is asignificant increase

122 Rural Action Group The Canadian OHS website gives information about the decibelscale http://www.ccohs.ca/oshanswers/phys agents/noise basic.htmlTable 3 states that a 3dB increase doubles the noise, a 10 decibelincrease is a 10 fold increase in noise and a 20B increase is a 100-fold increase in noise. Night time noise levels for Cardiff arepredicted to increase by at least 6-8dB and Collie Burn by at least 9to 16dB (see above). For Cardiff this is a four to eight-fold noiseincrease and for Collie Burn this is a 10 to 32-fold noise increase -from near the limit of measurement to the maximum night timeprescribed level.

124 Rural Action Group That PCF models the noise for Cardiff and Collie Burn undercalm/light wind and temperature inversion conditions.

125 Rural Action Group The noise receptors 'not verified' must be verified

126 Rural Action Group The noise levels and impact of noise at Stockton Lake is notacceptable

127 Rural Action Group Inadequately addresses noise emanating from the construction ofthe waste water pipeline and not construction of the plant itself. A fullimpact of assessment of noise from construction of the Shotts plantis modelled and discussed.

http://www.ccohs.ca/oshanswers/phys



128 Rural Action Group RAG believes that noise levels at Stockton Lake of 50dB, triple thenoise level at which it is not possible for the average person to sleep(45dB), are unacceptable

129 Rural Action Group The PER dismisses the value of Stockton Lake (Section 8.3.1)"Stockton Pool (sic) does not warrant special protection from noiseas natural quiet is not part of the intrinsic value of this place".

130 Rural Action Group Cardiff and Collie Burn are valued by the residents for the naturalquiet that is part of the intrinsic value of these places, and thereforeby the PER's own line of argument (Section 8.3.1), they do thereforewarrant special protection from noise.

131 Rural Action Group Perdaman proposes a target noise level of 65dB at the urea plantboundary (Section 8 .3.1). It does not say whether this is LA10 orLAmax. To propose a target based on achievable levels isunacceptable. Noise limits should be decided in advance for anyland used as an industrial site and based on minimizing loss ofamenity to residents. RAG understands other industrial sites in Collie(such as Coolangatta) have limits of 35dB at their boundary.

132 Rural Action Group RAG believes the noise levels emitted by PCF should follow theEPA's industrial estate guidance (http://www. epa.wa .gov.au/docs/2495 GS8.pdf) Section 3.2.1 Cumulative Noise) and bebelow 5dB less than the normally prescribed level at any receivingpremises.

133 Rural Action Group RAG does not believe the PER shows a design that preventsemissions causing an adverse environmental impact beyond theboundaries of the site.

136 Rural Action Group RAG does not believe that the PER shows a design that preventsemissions causing an adverse environmental impact beyond theboundaries of the site.

138 Rural Action Group Could PCF confirm that all ammonia emissions from the plant havebeen included in the modelling that these emissions represent worsecase ammonia emissions and modelling is under worst case weatherconditions as they specifically relate to Collie.

139 Rural Action Group Concerned that may be a risk to the community from long termammonia emissions

141 Rural Action Group Appendix D Section 7. 1.5 states ammonia emission modelling wasdone using AUSPLUME. Section 7. 3.1 states " Irwin's `rural' windprofile exponents were used". We do not understand this statementand would like to know if the modelling was applicable to winds andweather in the Collie area, which are detailed in Appendix D Section4.3.2 Figures 5-9.

142 Rural Action Group PCF revisit the statement that: "based on the isolate nature of CollieUrea Plant Site and surrounding land uses, dust emissions are notconsidered to represent a significant source of emissions" Collie islong 7km from the proposed site and is therefore not an isolated site.

143 Rural Action Group RAG requests real time particulate monitoring and reactivemitigation measures are employed for both breathable particulatesand nuisance dust. RAG requests that all dust monitoring is carriedas per Australian standards regarding the calibration of equipmentand location of monitors.

144 Rural Action Group RAG request that audible alarms are connected to the computeriseddust monitoring system so that any exceedances can be dealt withimmediately.

145 Rural Action Group Has PCF considered limiting construction activities to daylight hoursonly as respirable dust issues would be worse over night and in theearly mornings.



146 Rural Action Group Would PCF and the EPA confirm that no dust would be emitted inthe operational phase of the proposal other than PM10 and PM 2.5modelled in Appendix D.

147 Rural Action Group Contingency for water use not clear if there are dry years, given thatthe operations are reliant on surface water.

148 Rural Action Group No mention is made in Section 3.4.7 of replacing salt water takenfrom the Collie Basin with fresh water is made. That an amendmentis also made to the PER based on the advice from the DoW thatPCF will take up to 6 GL from the East Collie Diversion scheme suchthat there is no adverse impact on the river ecology or amenity.

149 Rural Action Group RAG would prefer that dry cooling is used. The arguments putforward by PCF against dry cooling are not totally logical. Thesubmission puts forward three arguments in favour of dry cooling.

150 Rural Action Group It is ironic that the much lauded "carbon capture ready, clean coaltechnology" geosequestration technology mentioned in the PER willrequire the transportation of carbon dioxide about the same distanceor further. This will obviously cost far more than pumping water andhas less direct benefit to the proponent. Does it not follow then thateven if geosequestration is ever proven possible, the transportationof carbon dioxide gas for geosequestration will also be dismissed astoo expensive by PCF?

152 Rural Action Group The PER does not adequately address potential pollution ofgroundwater and surface water in relation to either normal operatingconditions or plausible accident scenario's, particularly with theemitting of 1400t of ammonia per annum.

153 Rural Action Group How will PCF ensure that the waste water storage does not leach oroverflow into either groundwater or Stockton Lake.

155 Rural Action Group RAG requests that PCF considers restricting train movements to daytime hours. Outside school times school children are on roads andpreferably outside of main shift change times at other large industrialsites. RAG is concerned that no analysis of train movements duringthe operational phase of the plant was undertaken.

156 Rural Action Group RAG has serious concerns regarding the scope, nature of and dataused in the risk assessment provided in the PER by PCF. The'affected' population is grossly underestimated. RAG urges that anIndependent risk assessment is undertaken accounting for thematters raised in the RAG submission.

157 Rural Action Group RAG is of the view that this submission is not approved until acomprehensive risk assessment is completed.

158 Rural Action Group The PER states the "affected population" is assumed to be allresidences and businesses within 5km of the proposed site,estimated at 120 persons including Stockton lake recreational area(Section 6.13.3). This is a gross underestimation.

159 Rural Action Group The PER risk assessment dispersion modelling results (Appendix KSection 4.6.2) show areas that would be affected by Scenario 1 and2 as <2000m. Scenario 3 results show a maximum of 8000m. Basedon reports of ammonia releases found on the internet and on basicdispersion models provided by the US EPA, RAG believes thesefigures are vastly underestimated.

160 Rural Action Group An accident, equipment failure or sabotage at Perdaman 's plantresulting in the release of 10,000 tonnes of ammonia, more than10,000 times as much as at Karratha - would obviously becatastrophic. For the PER to conclude only a 1-25% risk ofpopulations within 5km of the plant being affected during theaccidental release of up to 10 , 000 tones of anhydrous ammonia (PER Appendix K, Section 2.9.3) is ridiculous.



161 Rural Action Group The PER risk assessment (Section 6 and Appendix K) appears to beextraordinarily underestimated as it only considers the area likely tohave very high fatalities in the event of an accidental ammoniarelease, i.e. concentrations down to 2310 ppm ammonia.

162 Rural Action Group In communications with PCF they state the probability of theammonia tank catastrophically rupturing [3.42E6 (Appendix K,Section 2.6.2)] has now been halved to <1E-11, as since the PERwas written they have decided to use a double-skinned tank (letter toRAG representative dated 2/10/09 from Gary Watson). PCFemphasises the low likelihood of a both skins of a double-wall tankspontaneously rupturing at the same time; we agree both inner andouter skins are unlikely to do so at same time. But they have notconsidered much more likely causes of an accidental ammoniarelease such as pipework and fitting failures (Appendix K Section2.6.3). Neither have they considered much more likely causes suchas human error, refrigeration failure causing the ammonia tovaporise and pressurize the tank, overfilling the tank,truck/aeroplane crashing into tank, sabotage/terrorism,earthquake/subsidence, bush/industrial fire, explosion in anotherpart of the process etc etc, the effects of most which would not behighly mitigated by a second skin on the tank.

163 Rural Action Group Despite Appendix K Section 4.6.2 Table 4.7. showing the distancefrom source of an ammonia plume released as Scenario MAE 3being 2310ppm (10 times the level considered seriously damaging tohealth) at 8km away, and despite the very limited considerationsused in the risk assessment, it concludes "No risk" to Collie outskirtsfor MAE1 and MAE2 and only 15% risk of the incident affectingCollie outskirts for MAE3 Appendix K Section 2.9.3. Since theprevailing wind (about 35% of the time) is shown in the PERAppendix D Section 4.3.3 as SSE to ESE, ie the very direction ofCollie townsite from the proposed site, this seems to beunderestimated.

165 Premier Coal The PER has not established whether the proposed urea productionplant would require a buffer zone that could potentially restrict miningor other industrial activities bordering the Shotts Industrial Park.

166 Premier Coal Premier Coal's coal handling facility, administration building andworkshop is located about 1.3km from the closest boundary.Appropriate risk management and emergency response strategiesmust be established and communicated for all people at or near theShotts Industrial Park.

167 Premier Coal If appropriate the use of void WO5H is possible. Verve currently usea proportion of this recharge for process purposes. Detaileddiscussions would be required before this could occur.

168 Premier Coal Arrangements will be required and formalised to ensure that worksoccur safely and are totally independent of Premier Coal'sjurisdiction (where work is to directly occur on Premier Coal land)

169 Premier Coal The vented waste gas from the product island may have a pungentodour. PCF is requested to assess the potential impact of waste gasagainst ambient air quality and that mitigation strategies, includingpossible shutdowns be considered to limit the impact of such anevent.

170 Premier Coal There is little detail as to how rail movement during peak trafficperiods will impact local traffic. A traffic management plan isrequested to be developed with Premier Coal to consider theinteraction between rail movements and peak traffic periods.

171 Premier Coal Premier Coal requests that PCF considers the installation of sliplanes on the Collie -Lake King road to reduce the impact of othertraffic using the road.



172 Premier Coal The estimated offsite population appears to have been understatedfor the PRA and air quality assessment. Premier Coal requests thata detailed risk assessment is undertaken using more accurate offsitepopulation data and Premier Coal buildings be considered assensitive receptors for air quality assessment before theseassessments are made to government.

173 Glyn Yates Noise emissions will need to meet all the established guidelines allof the time. These should be reported to the community on aquarterly basis through the local press.

174 Glyn Yates Air emissions will need to meet all the established guidelines all ofthe time. These should be reported to the community on a quarterlybasis through the local press.

175 Glyn Yates Clearing of the site should be undertaken in such a way to preventany over clearing but should be done in such a way as to ensure thesafety and security of the people and the plant is not compromisedas a result of regrowth and bushfires.

176 Glyn Yates Water is not to be drawn from the Collie Basin as this needs torecover as it is over depleted.

177 Glyn Yates The community is very concerned about the risks of an ammoniaaccident. These concerns should be acknowledged and appropriatestrategies to mitigate the risk should be developed and given to thecommunity.

178 Glyn Yates What steps will be taken to manage the 3.2mt of CO2 emitted ifgeosequestration is not an option.

179 South West Environment Centre The PCF does not meet the essential water resource managementto reduce, reuse and recycle.

180 South West Environment Centre The proposal does not provide any direct offsets for carbonemissions not does it consider or contribute to Federal Governmenttargets for reduced GG emissions. The proposal provides norealistic sequestration means, targets, actual or aspirational forcarbon pollution reduction.

181 South West Environment Centre SWEC notes that nowhere in the PER does the proponent attempt toreduce its water use from 12 L per annum. SWEC maintains that thiscould be achieved by using dry cooling methods or hybrid coolingsystems, potentially reducing water consumption by a minimum of50%

183 FoESWA Ocean outfall should not be considered. 12GL is excessive. Salinityand contamination quality conversion will increase energy useresulting in further emissions.

185 FoESWA Loss of embedded carbon and further loss of native forests andhabitat is unacceptable.

186 FoESWA The continued use of urea is unacceptably as there are high risksassociated with this product.

187 FoESWA The risk of a train accident on a steep grade and the risk of ureabeing washed into the Collie River and then the Leschenault Estuaryand ocean is a major concern.

188 FoESWA The use of fossil fuels to transport the fertiliser across the world andthe impact of shipping polluting both the oceans and atmosphereshould not be supported.

189 DoW The PER omits to consider dry cooling as a possible technology.This needs to be addressed.



190 DoW The DoW will assist the proponent to develop a comprehensivewater management strategy as a condition of any s.5c licence.

191 DoW An urban water management plan is expected to be a condition ofapproval for the project.

192 DoW DoW does not support the storage of wastewater on site. DoWexpects that the treatment and disposal of wastewater from theproject's operations will be given a high degree of scrutiny by theEPA.

193 Department of Mines and Petroleum Risks Presented in this facility may not meet the EPA off-siteindividual risk criteria for fatalities from hazardous plant

194 Anonymous email dated 4 November 2009 (ref. 2) The proponent does not release a figure to how much of its emittedgreen house gases will be abated from its plant

195 Anonymous email dated 4 November 2009 (ref. 2) The proponent mentions investigations into wind farms and bio-diesel in India. Under the proposed CPRS scheme, emissionssaving from outside Australia is not permitted to be used to offsetemissions generated in Australia

196 Anonymous email dated 4 November 2009 (ref. 2) I am interested in what price of carbon the plant becomes unviablefor operation and what conditions of operation will be placed on thisdevelopment approval.

197 Anonymous email dated 4 November 2009 (ref. 2) Details of how the plant plans to interact with the proposed CPSRscheme should be released.


Appendix B

Collie Urea Plant PER Submissions


Appendix C

Air Quality Report


Appendix D

Flora Report

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